Policy A15 Loxwood

Upgrades to the waste water and sewage need to occur before more houses are even considered.
A well stocked village shop needs to exist.
Public transport needs to be available and practical.

Loxwood is not a service village. It does not have a village shop or public transport links to the surrounding villages/towns unless you count the one bus per day for 4 days of the week!
CDC did not consult on revised housing numbers in North of the district which shows the Chichester locals are trying to pass the problem up the road.
Allocation of 220 houses plus a further 91 houses on already allocated sites is not sustainable in rural Loxwood
Transport infrastructure non existent, lack of sewerage capacity, school, doctors, shops do not have capacity.

Look at a scheme which minimises car use and maximizes the available of employment,infrastructure, amenities and proximity to other major conurbations. Consider although outside your remit, Petworth, as a huge historically underdeveloped opportunity which cannot be ignored when reviewing this area.

The proposed scale on top of the existing commitments (both completed and in progress) will ruin the village and create a dormitory car dependent settlement. The village is not equipped or enabled to facilitate these additional houses and lacks scalable infrastructure to cope with the ensuing demands such scale will bring. Loxwood is comparatively a remote location and is totally unsuitable for this huge increase.
Other locations would better absorb these numbers without the environmental consequences and associated climate emergency,which is much highlighted in your plan! Valuable and productive farmland loss, should also be considered here as an issue.

Stop targetting of Loxwood by WSCC and CDCC. It seems like the village is constantly under siege at the moment from developers

This proposal for additional housing in Loxwood is obscene. Adding this number of houses to an otherwsie quiet, rural country village will desecrate our local community
- Lack if infrastructure will not support this level of development
- Roads, sewerage, water, power supply are all insufficient as they are currently
- There is no public transport. 1 bus per day, on only 4 days per week is NOT a "service"
- Flood risk. My house was flooded due to excess run off caused by over development

No further building of houses in Loxwood with out appropriate consideration of the impact on the local community, availability of appropriate infrastructure, shopping facilities, public transport, road traffic volumes, impact on flood risk with in the village, sewer capacity,views of the majority of Loxwood residents

Plan does not comply with current planning regulations; meet CDC's own Sustainability Appraisal report in respect of infrastructure or environmental considerations; enable delivery of sustainable development; and was not based on any consultation with LPC.

This policy needs to be removed as it is not workable and if it were to proceed the damage to the historic village of Loxwood would be irreversible and terrible for the local residents both mentally and physically

Policy A15 is unworkable.

The Local Plan should comply with all other relevant requirements of the Planning and Compulsory Purchase Act, 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012, as amended. It does not.

The plan will not meet the CDC’s Sustainability Appraisal report as when judged against other reasonable options,
it does not help to achieve CDC’s environmental, economic and social objectives through lack of infrastructure and sustainability and does not meet meet environmental requirements.

The plan is not consistent with National Policy and will NOT meet with the policies in the National Planning Policy Framework.

Addition to requirement 8 “…and that development will be safe for its lifetime and not increase flood risk elsewhere, taking account of risks from all sources of flooding and climate change impacts, as per…”

The Environment Agency are due to complete a property level resilience scheme for Loxwood in late 2023. This is a community that have suffered property flooding several times in the last 20 years. Policy requirement 8 is therefore of particular importance, and we would recommend that there are small additions to this requirement in the policy:

“…and that development will be safe for its lifetime and not increase flood risk elsewhere, taking account of risks from all sources of flooding and climate change impacts, as per…”

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 9). Developers will need to consult with Southern Water to understand if there is capacity for further connections to the Loxwood WwTW as the works may need improvements to reduce spills from storm overflows.

No further housing should be allocated to Loxwood until Southern Water have sufficiently upgraded the sewerage capacity.

I concur fully with all the concerns about policy A15 that have been raised by Loxwood Parish Council.

In particular, given that Loxwood already has 2 housing developments relying on holding tanks for the discharge of sewage, and also that Southern Water have no plans to upgrade the sewerage system serving Loxwood, no further new housing should be planned for Loxwood until the matter is resolved. Additional housing would only exacerbate what is already an unsustainable situation.

It is therefore recommended that the allocation of housing sites in Loxwood should be based on a higher growth scenario of at least 825 homes which should be delivered either through a Local Plan policy allocation or within an SPD, with a clear timetable of when the SPD will be produced by the Council. Site proposed.

1 Introduction
1.1 This representation provides a response to the Regulation 19: Local Plan Consultation in relation to the land at Headfoldswood Farm, Loxwood, RH14 0SX, as shown on the attached Masterplan Promotional Document, and hereon referred to as the site.
1.2 This representation will provide a written responses in relation the questions in the Regulation 19 Local Plan Consultation which directly relate to the promotion of our client’s land for future development.
2 Comments on Specific Questions/Tests
2.1 In response to the national planning legislation, this Regulation 19 Local Plan Consultation invites comments on three specific questions, and is the final consultation phase, before the Regulation 19 version of the Local Plan is submitted for examination.
2.2 This representation will respond on these specific questions, and then highlight how our client’s site could help fulfil the full housing requirement for the District to be delivered through an appropriate strategic allocation policy within the Council’s Local Plan or through an Supplementary Planning Document (SPD).
Is the plan ‘sound’?
2.3 Paragraph 35 of the National Planning Policy Framework defines the tests for soundness which requires the plan to be positively prepared, justified, effective and consistent with National Policy. These matters will now be considered in further detail in relation to the current consultation on the Regulation 19 version of the Local Plan.
Is the plan positively prepared and justified?
2.4 Policy S1 of the Draft Local Plan sets out the spatial development strategy for the District and how the Council will achieve sustainable growth over the plan period and Policy H1 sets out the housing target in response to the strategy. Both policies have been informed by the Sustainability Appraisal (SA) dated January 2023 and the Plan objectives, which are set out at paragraph 2.5.2 of the SA and the Council’s HEDNA (April 2022).
2.5 The SA then goes on to discuss the potential growth scenarios and confirms two points:
• Standard method housing figure for Chichester (excluding SDNP) is 638 dwellings per annum, or 11,484 in total over the Plan period
• The above figure is capped at 40% above the baseline need and that the uncapped figure is significantly higher than this at 884 dwellings per annum (dpa)
2.6 Of particular note is that point ii. above seeks to cap the overall housing increase by no more than 40% above the previously adopted LP housing figure of 435 dpa. The Local Plan then goes on to constrain housing numbers due to an alleged capacity concern along the A27 strategic road network. The Council therefore result in a constrained housing figure by virtue of the standard method ‘steps’ and also due to infrastructure capacity. It should be noted that the 435 dpa figure within the 2015 Local Plan was similarly constrained and an early review was the only basis for accepting this reduced housing figure. This early review did not take place.
2.7 In terms of the influence of the A27, this is the key matter that constrains growth within the southern part of the District. This is based on the evidence base documents that state that the road network cannot accommodate an annual housing figure of more than 535 dpa. This is a fundamental point and one that we do not agree and believe there is capacity to accommodate at least the local housing need within the highway network, alongside potential improvements identified for the following reason.
2.8 The Transport Study (January 2023) is the key document on which the Council rely upon to constrain their housing figure to 535 dpa. On review of this document, it is clear that the Council’s consultants undertook a sensitivity analysis as to whether the core scenario that supports the 535 dpa position in the local plan could accommodate a higher level of growth. The conclusion in paragraph 5.6.5 and 11.2.3 of the Transport Study appears to be that 700 dpa could be accommodated (in the southern plan area) by the mitigation proposed for the 535 dpa core test, with some additional, and as yet undesigned and not costed, mitigation works beyond those highlighted for the Bognor and Fishbourne roundabouts.
2.9 Accordingly, the Council’s own evidence base has undertaken the assessment and concluded that a higher growth figure could be accommodated on the A27, subject to appropriate improvement works. Given the testing of the higher growth figure, which appears to accommodate the higher growth figure, the exceptional circumstances to constrain growth, as set out at paragraph 60 on the NPPF do not exist and the Plan could be considered unsound on this point alone.
2.10 As a result of the above, the SA does not consider a scenario where the Council would meet its local housing need, nor a scenario where it exceeds its local housing need, which is of relevance given the scale of development expected for adjoining authorities, including the highly constrained SDNP.
2.11 It should also be noted that the draft Plan does not therefore address any need in relation to unmet need of neighbouring authorities and it does not contain evidence to suggest that these matters have been discussed with the adjoining Authorities. Notably, Arun District Council have confirmed that they will be objecting to the Plan and currently proposed on the basis that they have a significant housing need themselves. This is likely to be further influenced by unmet need from Chichester, who again are seeking to constrain housing requirements, which was the case in 2015 and the subsequent knock on from that was for Arun to address some of that need in their 2018 Local Plan.
2.12 Given that we do not accept that the A27 capacity matters present a ceiling in terms of housing delivery (based on the Council’s Transport Study comments and that of its own consultants), it is not accepted that the Plan and associated SA demonstrates reasonable alternatives have been considered and it is not therefore positively prepared, nor is their approach to housing figures justified.
Effective?
2.13 On the basis of the 535 dpa figure, it is considered that the selected areas for growth and figures are deliverable over the Plan period, however, as set out above, the plan area could accommodate a greater level of growth.
2.14 It should also be noted that the Plan relies on the delivery of Neighbourhood Plan and / or small site allocations DPD. This is set out under Policy H3 in the draft document. This states the following in terms of delivery:
If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the council will allocate sites for development within a development plan document in order to meet the requirements of this Local Plan.
2.15 The above is not precise and does provide any clear timetable for delivery within the Plan period. Whilst the strategy in the comments above could be effective, the Local Plan needs to give a clear timescale for completion of the supplementary Development Plan documents in order to give a clear timescale for this to be completed.
Is the plan consistent with National Policy?
2.16 On the basis of the comments above, the approach to selected sites for allocation based on the 535 dpa figure is considered to be consistent. However, due to the lack of evidence to demonstrate this, the 535 dpa figure should be capped. Given the A27 capacity points raised, the draft Plan does not appear to meet the exceptional circumstances allowed for at paragraph 61 of the NPPF to justify their alternative approach. The Plan as proposed is therefore inconsistent with NPPF when read as a whole.
3 Development in Loxwood
3.1 Our client’s land is located to the west of the village of Loxwood, which is situated to the northeast of the District. The High Street (B2133) runs through the village, connecting the A281 and A272. For a detailed context appraisal of the site and masterplan vision, please see attached the Masterplan Promotional Document. The site was submitted for the Council’s call for sites in February 2019 and is included in Council’s latest HELAA.
3.2 The Draft Local Plan defines Loxwood as a service village with local facilities and services, these include an infant and junior school, as well as a medical practice, a local shop and community facilities, including a village hall. The village has been identified in the Local Plan as a suitable location for a higher level of growth as it has suitable HELAA sites which could come forward through the Neighbourhood Plan process.
3.3 It is agreed that a strategic expansion to the west of Loxwood is the best option for growth in the north-eastern area of the District as there are fewer constraints within Loxwood in comparison to other villages within the north-eastern area of the District.
3.4 Policy A15 of the Draft Local Plan states that land will be allocated within the revised Loxwood Plan for a minimum of 220 dwellings and supporting facilities and infrastructure. This is based on a downwards adjustment scenario for Loxwood, but it should be noted this figure is closer to the lower growth scenario of 200 dwellings.
3.5 The Council acknowledges in the SA that the highest growth scenario of 1.650 homes could be justified but there are concerns regarding the deliverability of homes due the potential scale of allocations to meet the higher growth figure which in turn could affect the Council’s ability to deliver the housing within the five year period. However, the Plan currently seeks
to allocate reasonably sized housing allocations on a number of small-scale housing sites which by this logic could equally affect the Council’s ability to meet the Council’s five year housing supply. It is recommended that the middle, higher growth scenario of at least 825 homes is sought, which would allow for meaningful growth in order to meet the needs generated by the new community, such as the identified primary school. The higher housing figure would also provide the benefit of more affordable housing provision for the north-eastern area of the District.
3.6 Loxwood Parish Council have produced a revised Draft Neighbourhood Plan which seeks to allocate 126 dwellings plus 17 carried forward from the Made Loxwood Neighbourhood Plan, providing a total of 143 dwellings. The Draft Neighbourhood Plan was submitted to the Council under Regulation 14 in December 2020. It is noted in response to the Reg 19 Local Plan consultation, that Loxwood Parish Council will be objecting to policy A15 and the increased housing numbers of 220 dwellings on sustainability grounds, with specific reference to water neutrality. The recent Parish Council meeting notes also indicate that there is currently little appetite to undergo another Neighbourhood Plan review, which will likely require additional resource and cost.
3.7 There is concern that relying on the Neighbourhood Plan to allocate specific sites in Loxwood, will result in unnecessary delay to delivery of housing in this area given the points raised above. Policy A15 is not therefore considered precise and does provide any clear timetable for delivery in housing within Loxwood within the Plan period. It is therefore recommended that the allocation of housing sites in Loxwood should be based on a higher growth scenario of at least 825 homes which should be delivered either through a Local Plan policy allocation or within an SPD, with a clear timetable of when the SPD will be produced by the Council.
Water Neutrality
3.8 One of the constraints of the north-east of the District is the requirement is for all new development to meet water neutrality, to ensure that any new it does not impact further on the habitat site comprising the Arun Valley Special Area of Conservation (SAC) or the Arun Valley Special Protection Area (SPA) & Ramsar site, in terms of groundwater abstraction within the Sussex North Water Supply Zone. It is anticipated that further advice and a mitigation strategy will be created by the Council and its partners to demonstrate how developments can achieve water neutrality. However, at present applicants are required to provide a water neutrality strategy to demonstrate how the development can achieve water neutrality.
3.9 To provide the Council with reassurance that the site is deliverable despite this constraint, our client has commissioned an initial water strategy based on a development of approximately 250 dwellings which includes provision for offsetting. The initial strategy indicates that water neutrality could be achieved for development on the site through water efficient fixtures and fittings, reuse of harvested water through greywater recycling for flushing toilets and offsetting through water efficiency upgrades on an educational facility located within the Sussex North Water Supply Zone. It would therefore appear on the basis of the work undertaken to date, that it would be possible for future development on this site to achieve water neutrality.
4. General Policy requirements
Policy H11 Meeting Gypsies, Travellers and Travelling Showpeoples’ Needs - object
4.1 The above policy sets out a requirement for 124 pitches across the Plan period, which is to be provided for by allocation of pitches on strategic allocation sites proposing 200+ homes.
4.2 Whilst we understand that there may be a district wide need, we understand that the underlying rationale underpinning this strategic approach is that insufficient sites came forward as part of the Council’s Call for Sites process. However, whilst this tells us about availability of sites, it doesn’t dictate the appropriateness of locations for gypsy traveller provision. It should also be noted that the proposed allocations would not accommodate the overall need and there is no clear quantifiable policy requirement to deliver this need. Accordingly, the approach is not considered to be robust.
4.3 What is clear is that plots are currently available in other areas of the district that have not been taken up by the Council for allocation (namely HELAA ref. HBI0028).
4.4 From our understanding there appears to be a clear absence of information regarding the requirements for pitch provision in localities and the site specific needs that are required to be met. We have not yet seen any evidence from the Council in respect of engagement with the gypsy traveller community in respect of a desire to be located on suburban residential sites – which we consider would contradict with the typical locations of gypsy traveller pitches which are located on rural sites on the periphery of rural settlements.
4.5 Due to the scale and form of the site and specific access names (larger HGVs for static homes and touring caravans) it makes it very difficult to design and suitable means of access that does not appear overly engineered, within a residential housing estate. No consideration appears to have been given to how this can be accommodated within such a site.
4.6 At this time, we consider it would not be appropriate to include such provision until further evidence has been provided on suitability of the approach, need in this specific location and suitability as part of housing allocation of this scale, with a single point of access.
4.7 On the basis of the above, we object to the proposed policy requirement.
5. Conclusion
5.1 Our client’s land is ideally placed to be able to fulfil the sustainable expansion to the west of Loxwood and the much needed, identified housing within the north-eastern plan area. The site measures 57.334 hectares and can be considered as a strategic housing site, west of Loxwood, that would deliver a higher growth of housing within this village and would appear to be able to meet water neutrality requirements. This would also support the viability of the services and facilities in the northern villages. This could include a sustainable addition to the existing village of Loxwood, result in significant enhancements to its existing services and facilities, improved links along, and connectivity to the Wey & Arun Canal and provision of at least 825 homes.

See attached representation.

• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.

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.

The text should be amended to state ‘Land will be allocated for development in the revised Loxwood Neighbourhood Plan or Site Allocations DPD for a minimum of 220 dwellings and supporting facilities and infrastructure. This would provide the plan with more flexibility in the event the parish decides not to proceed with a Neighbourhood Plan review.

See attached representation.

Keep to existing building line to west of main road through village of Loxwood. Therefore no development on fields - HL X0016.

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

I write to object to the Chichester Local Plan published in February 2023 for public consultation.
There are a number of points that I feel have not been addressed correctly and which concern Loxwood in particular. In general, I object to the fact that so many new houses have to built in and around this area. We do suffer from the fact that large land owners occupy much of the mid-West Sussex landscape and the South Downs National Park occupies this as well, making development opportunities restricted to north and south. I am a regular visitor to Chichester and am appalled at the number of new homes being built there making the roads impossible at key times.
Loxwood has no infrastructure for further development other than that proposed in the local Neighbourhood Plan. There is not a shop other than one, fundamentally a butcher’s shop and very ‘high end’ and is too expensive for regular purchases of staple goods.
There are no buses other than one bus servicing Godalming Sixth Form College which terminates in Guildford. There is one bus returning.
There are limited employment facilities in Loxwood and the surrounding villages. People living here would travel to work in cars making an already-busy B road more dangerous than it is. There was a RTA at the junction of Station Road with the High Street yesterday (26th March 2023) necessitating visits by police cars and ambulances.
Both the local primary school and the doctors’ surgery have declared that they are at full capacity.
The problem of sewage spewing on to the road from new developments has been witnessed by me with raw sewage spilling on to the main road out of an outlet drain.
Regarding wildlife, the countryside around Loxwood supports plants such as orchids and bluebells and other wild flowers, and bats and newts and kingfishers can be seen here. Regarding the development proposed on farmland, there is an owl box fitted in a tree bordering one of the footpaths, but hidden from view. This has been supporting a family of barn owls for the 4 years it has been in situ. They are nesting there now and thrive. “Wild barn owls are given the highest level of legal protection possible under the 1981 Wildlife and Countryside Act. Penalties that can be imposed for criminal offences in respect of a single bird, nest or egg contrary to the Wildlife and Countryside Act 1981 are an unlimited fine, up to six months imprisonment or both.”
There are so many other objections to over-development that they are too numerous to mention here and are well documented by other replies, I am sure. The area is becoming so crowded in terms of road use, water use and I feel strongly that more development is simply not sustainable.

Seek further clarification in Policy A15: Loxwood to emphasise importance of collaborative working between stakeholders to mitigate against the potential cumulative impact of development.

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

Policy S1 Spatial Development Strategy

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

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

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

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

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




Policy NE16 Water Management and Water Quality

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

Policy NE17 Water Neutrality

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

Policy H1 Meeting Housing Needs

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

Policy H2 Strategic Locations/Allocations 2021 -2039

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

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

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

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

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

Policy A15 Loxwood

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

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

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

I write to register my objections to the Local Neighbourhood Plan.

The developments that are already underway should be sufficient. The developments that have taken place over the past 15 years have already changed the nature of the village, making access to the local countryside, one of the intrinsic attractions of living in Loxwood, increasingly difficult. Loxwood was a village but ongoing development is turning it into a town but without improvements to amenities or infrastructure.

CDC is aware that there is limited opportunity for growth in Loxwood and any growth will have a negative impact on the village, its residents and the surrounding area.

My objections relate to Policy A15 and Sections 10.66 to 10.77. The policy would have a direct, negative impact on Loxwood. In my opinion the Local Neighbourhood Plan does not help achieve CDC’s environmental, economic and social objectives for the following reasons:

lack of infrastructure
environmental requirements are not met

There is a lack of amenities in the village at present, it has no Post Office or village convenience store. The local school and doctors’ surgery are at capacity and cannot cater for any increase in numbers using their services that would arise from m ore development. There is a lack of sewage capacity in the area; further development will place that system under further strain. Foul sewage escaping from the system is already blighting the lives of residents. A solution to the capacity issue has been cobbled together, with a holding tank serving the Nursery Green development that needs to be emptied by a tanker multiple times a week. This in itself leads to more HGV traffic through the village. Clearly there is already too much traffic passing through the village due to the introduction of traffic calming measures with new road markings being instated recently. Further development in Loxwood will lead to more traffic using the B2133 with negative impacts on the local environment as a result of more emissions from an increased number of motor vehicles in the area.

A negative impact on the natural environment would arise from the loss of hedgerows and ancient woodlands if development expands across land neighbouring the village, especially to the West. Further development of the village will destroy habitats for wildlife in the area including 79 internationally and nationally protected species that are known to live in the area including bats, newts, dormice, badgers, and other flora and fauna including birds on the Sussex notable bird list.

I object to any further development in the Loxwood area because it would ruin the nature of the village with detriment to residents already living in the village because there is inadequate infrastructure to support the development, and the negative impact on the natural environment.

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.

Reduce allocation at Loxwood. Reg 14 NP uses numbers from Preferred Approach Plan.
Chichester should look at converting the significant number of vacant retail and office properties in town and city centres into accommodation to serve an aging population.

I would like to object to the changes to the Chichester Local Plan 2021-39 covering the Loxwood ward on the following grounds.
• Loxwood has developed its own plan which has been approved. Overriding this plan makes a mockery of local decision making, which the local community has spent significant time developing.
• Chichester should look at converting the significant number of vacant retail and office properties in town and city centres into accommodation to serve an aging population that will require better access to services rather than converting the countryside into an urban sprawl.
• As a country with one of the lowest bio-diversity scores in Europe, over-developing the countryside will not improve this. We are increasingly pushing wildlife to the margins, including endangered species.
• The plan does not comply with various regulations and should therefore not go ahead.
• The infrastructure in Loxwood will not be able to cope with the significant increase in the number of houses and residents. There is no shop, the school and medical practice are already at full capacity.
• The sewage network will not be able to cope. On occasions I have witnessed raw sewage running down Guildford Road from Nursery Green. Southern water will not be increasing capacity for a long time.
• The flood risk associated with over-development should not be underestimated. The local water courses cannot cope.
• Water is already an issue and unless each of the proposed properties have a rainwater collection tank, which the developers will never agree to, we will see greater pressure on our water infrastructure.
• We are constantly promised that developments will generate some benefits for the local residents, but these benefits rarely materialise. Traffic calming only amounts to some flashing signs that do not deter drivers from speeding and the road markings recently introduced have not made any difference. Frankly, it’s lip service and a complete waste of money.
• There is no meaningful public transport. No one who works outside the village 9-5 would never be able to get public transport to work. You would have to leave home Friday lunchtime to make it to work by 9am Monday morning if you do not work in Loxwood.
• Instead of building more houses on the proposed sites we should be putting up solar panels. That would benefit the local community and wildlife would be able to live alongside this.
• Local footpaths and bridleways will be affected to the detriment of frequent users.

I write to register my objections to the Local Neighbourhood Plan.

The developments that are already underway should be sufficient. The developments that have taken place over the past 15 years have already changed the nature of the village, making access to the local countryside, one of the intrinsic attractions of living in Loxwood, increasingly difficult. Loxwood was a village but ongoing development is turning it into a town but without improvements to amenities or infrastructure.

CDC is aware that there is limited opportunity for growth in Loxwood and any growth will have a negative impact on the village, its residents and the surrounding area.

My objections relate to Policy A15 and Sections 10.66 to 10.77. The policy would have a direct, negative impact on Loxwood. In my opinion the Local Neighbourhood Plan does not help achieve CDC’s environmental, economic and social objectives for the following reasons:

- lack of infrastructure
- environmental requirements are not met

There is a lack of amenities in the village at present, it has no Post Office or village convenience store. The local school and doctors’ surgery are at capacity and cannot cater for any increase in numbers using their services that would arise from more development. There is a lack of sewage capacity in the area; further development will place that system under further strain. Foul sewage escaping from the system is already blighting the lives of residents. A solution to the capacity issue has been cobbled together, with a holding tank serving the Nursery Green development that needs to be emptied by a tanker multiple times a week. This in itself leads to more HGV traffic through the village. Clearly there is already too much traffic passing through the village due to the introduction of traffic calming measures with new road markings being instated recently. Further development in Loxwood will lead to more traffic using the B2133 with negative impacts on the local environment as a result of more emissions from an increased number of motor vehicles in the area.

A negative impact on the natural environment would arise from the loss of hedgerows and ancient woodlands if development expands across land neighbouring the village, especially to the West. Further development of the village will destroy habitats for wildlife in the area including 79 internationally and nationally protected species that are known to live in the area including bats, newts, dormice, badgers, and other flora and fauna including birds on the Sussex notable bird list.

I object to any further development in the Loxwood area because it would ruin the nature of the village with detriment to residents already living in the village because there is inadequate infrastructure to support the development, and the negative impact on the natural environment.

Please accept this email as an objection to the proposed overdevelopment of Loxwood, and listed below are just a few of the considerable number of reasons further development should be stopped and a Loxwood Plan implemented.

Current developments are not able to be built because of considerable ongoing and yet to be remedied issues with sewage, water supply, wastewater, (as previously highlighted by Southern Water and Natural England) lack of facilities, risk of flooding, lack of sensitivity of the history of the village and its surrounding natural environment, no transport infrastructure, total lack of consideration to wildlife, school and doctor surgery at maximum capacity, to name just a few.

I strongly object to any further development which will only compound issues listed above together with many more, and wish my objections to be noted against Policy A15 section 10.66 to 10.77 within Chapter10 Strategic and Area Based Policies as having a direct impact on the village of Loxwood.

I wish to add my objection to this housing development that was recommended by CDC.
CDC was supposed to carry out a study on growth scenarios for housing in Loxwood and to share their findings in a consultation back in 2022. The above to date didn’t take place, despite LPC continuously chasing for the above study.

Loxwood as a village can not sustain such a development this is due to the poor infrastructure already in place, there are no shops, no public transport, no street lighting, extremely basic services I.e. sewage system, waste water collection, fresh water supply. The national grid already struggling, we are also surrounded by country lane and not main roads. The local school and surgery are running over there capacities.

I think CDC are conducting the business in reverse and putting their interests before the people of Loxwood.

I wish to strongly object to the recently published local plan. My reasons for this are:

1 Loxwood is NOT a service village.
• Our village shop has closed.
• Public transport is very limited and often cancelled with no warning or communication.
• The doctor’s surgery is at full capacity.
• The surrounding (narrow country) roads cannot cope with additional traffic.
• There is no additional capacity for sewage.
• There is a lack of water capacity.
• We have too many new builds which are stretching the resources of this little village.
• There is a risk of flooding if further building work is carried out.
• Further housing for low income families and the elderly is short sighted as they will need their own transport to carry out their daily lives (there is no village shop and few buses).
• We have no cycle routes (my husband and I are keen cyclists – we would have noticed if there were).
• Footpaths would be reduced ... a key attraction of this area is the walking opportunities.
• Wildlife habitats will be destroyed.

Policy A15 should be removed and Policies H2 and H3 amended to reflect a realistic allocation of 125 houses which is still generous compared to other local area with better services.

I feel very strongly the local plan is ill thought through and a unbalanced distribution of houses that doesn't reflect the nature of rural villages. Loxwood is a rural village with no public transport links that are usable for the working population, no work opportunities, a serious lack of sewage capacity, no local grocery shop and yet the council deem it suitable for over 312 houses which will give a 50% increase in dwellings and a potential for significantly more as a 'strategic' location-it is completely bonkers. We are not a town!

It is also very disrespectful of the council to ignore our latest neighbourhood plan-we have accepted the national need for additional houses and have spent significant time and funds to produce this. It has completely demoralized the parish council and make a mockery of the whole process.

I have included my comments below why i believe this is not a viable plan for the council.


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

Policy A15 should be removed and Policies H2 and H3 amended to reflect a realistic allocation of 125 houses which is still generous compared to other local area with better services.
Loxwood should not be deemed to be a strategic location-it is a small rural village
LPC have spent time and effort to create a Revised Neighbourhood Plan which allocates 126 houses plus 17 carried forward from the Made Neighbourhood Plan giving 143 houses. It has reached Regulation 14 consultation stage and is based upon the Preferred Approach Local Plan consultation. The residentsof the Parish and Loxwood Parish Council have satisfied themselves through evidence gathered that 126 homes is a sustainable allocation given the constraints that exist-it should not be ignored due to water neutrality issues
This protects the village and the community and reflects the importance of Neighborhood plans for Loxwood and the rest of the country -there is a process and it should be respected otherwise it makes a mockery of the whole planning system and developers win every time.
Please can you protect the rural nature of this county and vote against plan.

Plan should allocate sites.

See attached representation.

I am writing to you with VERY strong feelings against the Chichester Local Plan 2021 to 2039 specifically
for Loxwood. As a resident of 45 years, I have experienced the changes, many of which have been negative, that have happened over
that period in Loxwood.
Leaving aside the shortcomings of the previous approved housing developments by CDC, I would like to briefly identify the shortcomings in the Local Plan 2021 to 2039 for Loxwood.
Having read the
The village infrastructure is already lacking shops, transport links, development of sewage and wastewater facilities by Southern Water,
as well as current pressures on the school and medical centre. These all need to be improved BEFORE and new developments are approved and the proposed infrastructure delivery plan in the A15 policy and 10.70 of Chichesters propose plan is not at all specific and
lacking in areas I have mentioned above.
New housing in Loxwood will have a negative effect our local and the wider environment and will fall outside of current government legistation for hedgerow regulations, conservation of species and habitate, as well as the much discussed requirement for water neutrality.
There is so much wrong with these proposals, as I have highligted that it makes a further 220 houses in Loxwood totally unworkable.

I am writing to comment on the allocation of 220 houses in the Local Plan for Loxwood.

Astounded are my thoughts that the powers that be think that we can cope with 220 more houses on top of an influx we have already received. My various reasons why our infrastructure cannot cope I list below.

1. We have no shops other than butchers and hairdressers. I know there is a plan for a new shop in the village but this has been going for some time and I cannot believe it will actually happen.

2, The village has no bus service to speak off.

3. The school cannot cope with the extra pupils that would be generated.

4. We already have problems with water and sewage in the village and this has not been adequately dealt with.

5. The Doctors Surgery is struggling already.

6. The roads are already in a very poor state and could not cope with the extra traffic.

It feels that as we are on the edge of Chichesters area we are like the forgotten people and are becoming a ground for dumping any extra housing with no real justification that the area can cope.

Loxwood Ward is an under-funded, under-serviced rural area. I fail to understand how the housing numbers mentioned in this Local Plan can be seriously considered for this rural area where there are so many ongoing issues waiting to be addressed. These problems have been created by the recent expansion of housing in the ward.

It is irresponsible planning to propose further expansion until existing infrastructure is improved to cope with the current level of housing and population. Loxwood and the surrounding villages are in danger of being swamped. Public transport. Employment. Schools. GP surgery. Water neutrality. These are not small things to be dismissed as ‘easily dealt with’ in the bigger picture of this Local Plan. These things affect the daily lives NOW of all of us who live in this Ward and must be addressed.

Infrequent and rarely seen public transport. Increasing traffic usage on often narrow rural roads and the accompanying reduction in air quality. Vehicles that ignore speed limits and endanger other road users [walkers, children walking home from the school bus stop, joggers, cyclists, horse riders]. I have lost count of the times I have walked to Ifold Stores along Plaistow Road and have been passed within 1ft by cars and vans exceeding 30mph. Not to mention the seriously overwhelmed and under-staffed GP surgery.

Loxwood is not a ‘service town’ with transport links, it is a small village without a shop selling basic groceries. We have seen a succession of housing plans submitted locally that boast water neutrality but without evidence of how this will realistically be achieved. Developers are looking to get rich at the expense of residents.

It is scandalous that the CDC should allow this to happen without due oversight and consideration of the local population. The draft of this Local Plan should be compiled after repeated on-site visits and thorough research, in consultation with local representatives, and not by someone sitting at a desk in Chichester using Google.

Allocation should be removed in favour of allocations elsewhere in the Southern Plan Area.

See attachments.

Please add our names to the objectors list regarding the plan to add another 220 houses in LOXWOOD, our village in your constituency.

We are being threatened on all sides, and we have no facility for expansion. There are plenty of building opportunities that are adjacent to larger roads, we are small village community.

In summary, my objections are these:
• We are on a junction of two B-roads, not big enough for big housing development
• The school is full, with a waiting list and no room to expand
• The doctors surgery is full to bursting
• Loxwood floods badly
• The sewers are too small to cope with the village as it now is
• We have ongoing water neutrality issue that do not fit with plans to bring more houses to the village
• Fresh water supplies are stretched to the maximum as it now is
• There is no gas
• There is no shop
• There is no public transport
• We are entirely car-dependant, and more homes bring more cars and air pollution

I have just heard that there is a planning application in for 220 more houses in Loxwood. I find this extraordinary when you consider all the things we don't have.
1. A shop, I have just driven 3 miles each way to buy a paper.
2. There is no bus service here at all on at least one working day connecting Loxwood to the nearest train station.
3. We are not water neutral and one development has an overflow sewage tank that has to be emptied by a lorry.

We do have:
1. A near capacity school
2. A near capacity surgery
3. No available local employment

There are a lot more examples I could have given as to why this is a bad idea for the area and also for the environment, but I am sure you have heard them all before.

See attached.