Policy A15 Loxwood

See attached written representation

A. SUMMARY AND CONCLUSION
1. The Council’s emerging Local Plan is unsound as:

• proposed Policy S1, Spatial Development Strategy (Appendix LPD1, page 38-39), focuses most future growth in the south of Chichester district in an area that is highly constrained in planning terms, with only a moderate amount of growth proposed in the North of the Plan Area which is objectively and comparatively less-constrained;

• proposed Policy H1, Meeting Housing Needs (Appendix LPD1, page 100), sets out a total housing supply of 10,359 homes for the plan period of 1 April 2021 to 31 March 2039, equivalent to 575 homes per year (an already capped figure due to highway constraints in the south). This is a shortfall of 1,134 homes for the plan period, or 63 homes per year, against the Council’s minimum local housing need as calculated by the Government’s standard housing method and set out in the Council’s Housing and Economic Development Needs Assessment (Appendix LPD2, page 42);

• the Council proposes a similar spatial strategy and shortfall in supply of housing against its full housing need to that for the previous (adopted) Local Plan (Appendix LPD3, pages 40 – 41, and 49). This has resulted in the Council being unable to demonstrate a five year housing land supply and manage proposals for speculative development, reflected in some 87% of new housing coming from windfall sites (Appendix LPD4, page 12), so is proven to be unsound;

• despite the historic and proposed shortfall in its housing supply, the Council presents insufficient evidence to demonstrate that the impacts of meeting more of the local housing need would significantly and demonstrably outweigh the benefits when assessed against the policies in the National Planning Policy Framework (2021), taken as a whole;

• the Council’s Sustainability Appraisal (Appendix LPD5, page 26) assesses growth scenarios in the North of the Plan Area. A growth scenario including Crouchlands Farm for 1,114 homes (or 62 per year) is found to be most sustainable (Appendix LPD5, page 34) but is discounted without clear and robust reasoning, and a blended growth scenario for 720 homes (or 40 per year) is proposed in the Local Plan (Appendix LPD5, page 40). It is wholly unclear how the Council has arrived at its decision;

• the Water Neutrality Mitigation Strategy (Appendix LPD6, page VI) and Emerging policy NE17 (Appendix LPD1, page 89) allows for 1,796 homes in the
North of the Plan Area, of which scenarios 1a and 2a, including Crouchlands Farm, are less than. Water Neutrality is therefore not a constraint when considering a higher level of development in the North of the Plan Area; and

• Crouchlands Farm was also assessed in the Council’s Housing and Economic Land Availability Assessment (Appendix LPD7, page 134) as being suitable, achievable and available for rural enterprise-led development / residential mix of up to 600 homes (HELAA ID HPI009).

2. The emerging Local Plan, therefore, is unsound due to it not being positively prepared by the Council in proposing a shortfall of housing supply against its minimum local housing need, where there are no exceptional circumstances to justify this, as well as there being evidence to support additional sites for housing, including at Crouchlands Farm. There is no coherent basis for the Council not taking forward Crouchlands Farm to increase future housing supply given the shortfall.

3. As a result, the Council should be asked to allocate more sites to help bridge the gap in the extent of its housing shortfall and Crouchlands Farm should be considered the obvious first choice given the deliverability of Rickman’s Green Village, as demonstrated by the Council’s evidence base (Appendix LPD5, page 34, and Appendix LPD7, page 134).

4. In addition, a wealth of technical work has been undertaken to prepare and submit three planning applications for Rickman’s Green Village (Chichester District Council reference 22/01735/FULEIA, 22/03114/FULEIA, and 22/03131/OUTEIA) that are currently awaiting determination. These applications further demonstrate the suitability of Crouchlands Farm as a highly sustainable site, capable of delivering up to 600 homes alongside a primary school (or other suitable community facility ), village hub with farm shop, cookery school, glamping and retail and commercial units, and open space provision, such that it should be allocated in the emerging Local Plan.

5. Artemis, or a representative thereof, therefore wishes to participate in the future hearing sessions for the emerging Local Plan. It is considered that as Crouchlands Farm is the only specific alternative considered in the Sustainability Appraisal, it merits its own hearing session.

B. EMERGING LOCAL PLAN ANALYSIS
Introduction

6. This representation has been prepared by DLBP Ltd, on behalf of Artemis Land and Agriculture Limited (“Artemis”), to object to the soundness of the Chichester Local
Plan 2021-2039: Proposed Submission (“the emerging Local Plan”) prepared by
Chichester District Council (“the Council”) for public consultation between 3 February to 17 March 2023 under Regulation 19 of the of the Town and Country Planning (Local Planning) (England) Regulations 2012.

7. Artemis is the owner and operator of Crouchlands Farm, Rickman’s Lane, Plaistow,
Billingshurst, West Sussex RH14 0LE, a 197 hectare livestock farm in the north of Chichester district partly proposed as the site of a new settlement, known as Rickman’s Green Village.

8. The representation is based on the adopted National Planning Policy Framework (2021). There is a draft version currently being consulted on, but even if approved as drafted, it will not apply to a Local Plan that has reached Regulation 19 at this point. Therefore, the draft policies are not referred to.

9. In the interests of conciseness, the appendices list is not exhaustive. For example, only a selection of the planning applications documents, or executive summaries of these, have been included. The planning applications are available on Chichester District Council’s website (planning refs 22/01735/FULEIA, PS/22/03114/FULEIA and 22/03131/OUTEIA), or a full suite of documents can be provided upon request.

Spatial Strategy

10. Proposed Policy S1, Spatial Development Strategy (Appendix LPD1, page 38 – 39), is unsound.

11. Proposed Policy S1 builds on the spatial strategy of the previous (adopted) Local Plan (Appendix LPD3, page 40 – 41) by focusing growth in the south of the District on sites in and around Chichester city, and the east-west corridor. The south of the district, however, is known to be highly constrained in planning-terms. Key constraints identified by the Council are the (lack of) capacity of the A27, flood risk, and the need to protect environmental designations, landscape quality, the historic environment and settlement character (Appendix LPD1, paragraph 3.5).

12. Due to the constraints in the south, in particular capacity issues of the A27, the Council proposes a moderate level of growth in the North of the Plan Area.

13. Previous advice from the Planning Inspectorate (Appendix LPD8, page 4) concluded that the Council should reassess its adopted spatial strategy and distribution of development in other parts of the District to establish whether the housing need could be met in another way. The emerging Local Plan, however, does not reassess the distribution of development sufficiently.

14. Proposed Policy S1 is unsound as the Council’s evidence base demonstrates that additional housing could be delivered in the comparatively less-constrained North of the Plan Area, including at Crouchlands Farm, so the proposed policy is not positively prepared, and nor is it appropriately justified. This is expanded upon further below.

North of the Plan Area

15. Proposed Policies A15, Loxwood (Appendix LPD1, page 260) and H3, Non-Strategic Parish Housing Requirements 2021 – 2039 (Appendix LPD1, page 103) are also unsound.

16. The emerging Local Plan proposes one allocation for housing in the North of the Plan Area, Policy A15, Loxwood, for a minimum of 220 homes to come forward over the plan period, all through the neighbourhood plan process.

17. Proposed Policy H3 sets out non-strategic targets for 25 new homes to be delivered over the plan period in Plaistow and Ifold Parish, 50 in Kirdford Parish, and 75 in Wisborough Green, all through neighbourhood plans (of which Plaistow and Ifold does not even have a draft Neighbourhood Plan) or subsequent development plans (which have not even begun preparation yet).

18. It is clear, when looking at the District’s population data alone that the North of the Plan area should, proportionately, take on more housing. This is because:
• the population for the entire District (excluding the South Downs National Park area) is 89,982 , which comprises 8,396 in the North of the Plan Area and
81,586 in the remaining south of the District;
• the emerging Local Plan proposes 10,359 homes over the Plan period, comprising 370 in the North of the Plan Area and 9,989 in the remaining south of the District;
• if the proposed housing was to be distributed evenly across the District, one home should be allocated per 11.5 people. An even distribution would therefore result in 966 homes in the North of the Plan Area;
• however, the Local Plan only proposes 370 homes in the North of the Plan Area. This is a shortfall of 596 homes against what should be provided (966 homes) if it were to be evenly distributed, which equates to a 161% shortfall.

19. Proposed Policies S1, H3 and A15 should be found unsound due to there being evidence (set out in the Council’s own evidence base and within this representation) demonstrating that additional housing could be delivered in the North of the Plan Area to meet future needs, particularly in the parish of Plaistow and Ifold at Crouchlands Farm.

20. Furthermore, proposed Policies S1, H3 and A15 are unsound as they are not justified or effective, but are overly reliant on the delivery of additional homes in the North of the Plan Area on sites allocated in neighbourhood plans for the respective parishes when there is no evidence to demonstrate that any sites are likely to be allocated, nor even that neighbourhood plans will be prepared by each of the parishes in the plan period. For example, proposed Policy H3 seeks to deliver 25 new homes in Plaistow and Ifold parish, however work to prepare its neighbourhood plan has ceased indefinitely.

Sustainability Appraisal

21. The Council’s Sustainability Appraisal (Appendix LPD5, page 34) considered the following six growth scenarios to determine the number of homes to be delivered across the four parishes (Kirdford, Loxwood, Plaistow and Ifold, Wisborough Green) in the North of the Plan Area:

i) 1, lower growth of only the four parishes providing 514 homes (29 homes per
year);
ii) 1a, lower growth of the four parishes plus Crouchlands Farm, providing 1,114 homes (62 homes per year);
iii) 2, higher growth of only the four parishes, providing 1,139 homes (63 homes per year);
iv) 2a, higher growth of the four parishes plus Crouchlands Farm, providing 1,514 homes (84 homes per year);
v) 3, highest growth of only the four parishes, providing 1,964 homes (109 homes per year); and
vi) 3a, highest growth of the four parishes plus Crouchlands Farm, providing 2,564 homes (143 homes per year).

22. The Council’s Sustainability Appraisal concluded that the Council is supportive of a blend of Scenarios 1 and 2 (Appendix LPD5, page 40).

23. To reflect this, proposed Policy H3 Non-Strategic Parish Housing Requirements 2021 – 2039 (Appendix LPD1, page 103) therefore seeks:
i) lower growth at Kirdford (50 homes) and Plaistow and Ifold (25 homes) on unallocated sites; and
ii) higher growth at Loxwood and Wisborough Green through a combination of one allocated site for 220 homes (proposed Policy A15) and other unallocated sites (75 homes).

24. However, Figure 1 of the Council’s Sustainability Appraisal (Appendix LPD5, page 34), above, very clearly shows that scenario 1a (lower growth of only the four parishes plus Crouchlands Farm) scores the best overall i.e., is the most sustainable option. This is due to scenario 1a scoring highest in regard to the site’s accessibility, communities and health, lack of heritage constraints relative to the other scenarios, as well as lack of landscape constraints relative to the other scenarios.

25. With regards to the analysis of the remaining criteria:
• Air Quality and Environmental Quality; Biodiversity; Land, Soils and Resources – whilst we appreciate the information may not be available for the ‘other areas’ accounted for in each growth scenario, the scoring does not reflect the information within the three planning applications at Crouchlands Farm (e.g. Ecological Impact Assessments (Appendices RGV17 and RGV18), Air Quality Assessments (Appendix RGV8 – RGV10), Environmental Impact Assessments
(Appendices RGV21 and RGV22), Agricultural Land Classification Assessment (Appendix RGV7), Land Quality Assessments (Appendices RGV26 and RGV27, etc));
• Housing – the scoring for this category is inconsistent with the other criterion, as it does not exclude option 3a from the ranking. For example, Scenario 1a should therefore score 4, rather than 5, if based purely on the quantity of homes. But page 4 of the Sustainability Appraisal (Appendix LPD5) confirms that the objective is to (our emphasis): “deliver suitable, well designed, energy efficient and affordable housing to meet local needs, in safe and accessible neighbourhoods with mixed and balanced communities”. In the absence of supporting evidence on the qualitative elements of this objective, other than at Crouchlands Farm, the method of scoring this criteria is unsound as it does not meet the full objective. When considering the high-quality design of homes at Crouchlands, it is clear that scenarios 1a and 2a should in fact score higher; and
• Economy, employment – the Sustainability Assessment fails to acknowledge the economic benefits proposed at Crouchlands Farm, which will have a significant economic benefit for Chichester District Council and the wider area. This is demonstrated in the Economic Impact Assessment submitted with planning application (Appendix RGV19). A second Economic and Social Value Impact Assessment as also been submitted which considers the scenarios of the whole of the proposal (Appendix RGV20), but we wholly appreciate that the Council did not have access to this at the time of preparing the Sustainability Appraisal.

26. There is a clear disconnect between the scoring of the scenarios, how each scenario and Crouchlands Farm has been assessed by the plan-maker, and how the conclusion to proceed with a blend of scenarios 1 and 2 has been made. Page 34 of the Sustainability Appraisal (Appendix LPD5) clearly states that it “is undertaken without any assumptions regarding the degree of importance, or ‘weight’, that should be assigned to each of the topics in the ‘planning balance’. It is only the Council, as the decision-making authority, that is in a position to arrive at an overall conclusion on the best performing growth scenario on balance”. One must therefore assume that the Council has assigned more importance and weight to certain criteria of the scoring. But there is a clear lack of explanation of this weighting exercise, so the results of the testing is not justified.

27. The Council’s reasoning for supporting a blend of scenarios 1 and 2 at section 7.3 of the Sustainability Appraisal (Appendix LPD5, page 40) is therefore wholly unclear, not justified, and is unsound.

28. In summary, the Council’s position is that:
• the government’s standard housing methodology determines an objectively assessed need of 638 dwellings per annum, or 11,484 over the plan period
(which is a capped figure at 40% above the ‘baseline’ need figure);
• the figure is then capped further to the plan area as a whole to 575 dwellings per annum, because:
• capacity constraints associated with the A27 in the south of the plan area results in a resolution that there is capacity for no more than 535 homes per year in the south (i.e. a further capping of its proposed supply);
• this means that 103 homes per year need to be made up in the North of the Plan Area, or 1,854 homes over the plan period;
• a growth scenario (1a) including Crouchlands Farm for 1,114 homes (or 62 per year) is found to be most the sustainable option in the Sustainability Appraisal when considering the score of figure 1 above (Appendix LPD6, page 34) but is discounted without clear and robust reasoning;
• the Council thus proposes only 40 homes per year in the North of the Plan Area due to ‘wide ranging planning reasons’.

29. This is wholly unsubstantiated as it means that there is a shortfall of 63 homes per year, or 1,134 homes over the plan period. Also:
• the Sustainability Appraisal (Appendix LPD5, page 16) sets out that water neutrality has implications for the growth quantum in the North of the Plan Area, so this area cannot accommodate the full 63 homes per year (which is already a capped figure);
• but the Water Neutrality Mitigation Strategy (Appendix LPD6, page 15, table 3.1), and the Sustainability Appraisal (Appendix LPD5, page 16), both confirm that the North of the Plan Area can accommodate 1,796 homes (circa 100 homes per year);
• and even if a suitably precautionary approach is taken (considering fewer homes, by 5% or 10%), 5% fewer homes would equate to 1,706 homes, and 10% fewer homes would equate to 1,616 homes;
• therefore, even with the highest buffer (10%) applied, 1,616 homes could be accommodated in the North of the Plan Area over the plan period (circa 90 homes per year). This means that almost the entirety of the actual shortfall (1,854 homes) could be reached in the North of the Plan Area.

30. We accept that the 1,854 homes required to be made up in the North of the Plan Area cannot be accommodated, due to water neutrality constraints and so scenarios 3 and 3a are discounted.

31. However, scenarios 1 (514 total homes), 1a (1,114 total homes), 2 (1,139 total homes), and 2a (1,514 total homes) would all be below the most precautionary approach taken to water neutrality constraint. Taking the highest growth scenario 2a (with Crouchlands Farm), there would still be headroom of 102 homes in terms of the Water Neutrality Mitigation Strategy.

32. Therefore, water neutrality cannot be the determining constraint for discounting scenarios 1a or 2a from the Sustainability Appraisal (Appendix LPD5).

33. Therefore, there is very limited explanation about what the “wide ranging planning reasons” are, and how the resulting shortfall has been reduced from 103 homes per year to 40 homes per year in the North of the Plan Area. Three examples are referenced (with our comments in bold):
• the rurality of the area – whilst we appreciate and wholly recognise this is a designated Rural Area under Section 157 of the Housing Act 1985, so are many of the sites in the south of the plan area that already have, and are planned to, accommodate significant growth. But other than this, a large part of the North of the Plan Area, including Crouchlands Farm, is unconstrained – it is not in the Green Belt, an Area of Outstanding Natural Beauty, a Special Area of Conservation, a Site of Special Scientific Interest, or other constraints. This is accepted by the Council at page 34 of the Sustainability Appraisal (Appendix LPD5);
• the entire area falls within a constrained water resource zone – this is not a constraint. The Council’s own proposed Policy NE17 contradicts this reasoning, as clearly sets out how developers can provide evidence that new development will be water neutral. In addition, Natural England’s Mitigation Strategy (Appendix LPD6, page V - XI) identifies the area as having capacity for 1,784 homes, and growth scenarios 1, 1a, 2 and 2a would all allow for headroom when considered against this (see paragraphs 28 – 32 above); and
• transport-related barriers to growth, whereby Waverley Borough and Horsham District have raised concern – as set out in Section C below, the planning applications at Crouchlands Farm contain a wealth of transport assessments and evidence that there are suitable, reasonable, and proportionate ways of mitigating this. Horsham District and Waverley Borough Councils and have not raised objection to the planning applications, either on transport or any other grounds (Appendices RGV40 and RGV41, respectively). Paragraph 5.2.33 of the Sustainability Appraisal (Appendix LPD5) accepts that the strategic growth options, i.e.
Crouchlands Farm, have merit in transport terms.

34. Further details of the Council’s assessment of Crouchlands Farm in the Sustainability Appraisal (Appendix LPD5) are set out in Section C of this representation, alongside our response to each of the points raised by the Council.

40 homes per year

35. A meeting was held between the Council and an Advisory Inspector in October 2022
(Appendix LPD9). This precedes the publication of the Sustainability Appraisal (Appendix LPD5), the growth scenario testing, and the Water Neutrality Mitigation
Strategy (Appendix LPD6), which have since concluded that development of up to 1,796 homes can be sustainably achieved in the North of the Plan Area over the plan period. The Sustainability Appraisal (Appendix LPD5) excluded scenario 3a on the basis of this being exceeded (page 26).

36. Nevertheless, paragraph 5 of the Advisory Inspector’s notes (Appendix LPD9) states “[…] the Council consider[s] a housing requirement below the need derived from the standard method (some 535 dwellings per annum (dpa) in the southern plan area and the potential for a further 40 dpa in the northern plan area compared to 638 dpa)”. And paragraph 9 lists a number of potentially constraining factors (e.g. limited public transport, limited facilities, water neutrality etc), which the Advisory Inspector states (our emphasis): “appear to support the Council’s position that a maximum of 600-700 homes could be delivered over the Plan period (or around 40 dpa).”

37. However, it is unclear what evidence informed the figure of 40 homes per year in the Advisory Inspector’s note, particularly as:
• none of the scenarios in the Sustainability Appraisal specifically tested a 40 homes per year scenario; and • the Water Neutrality Mitigation Strategy, restricting development in the North of the Plan Area to 1,796 homes was not published until December 2022.

38. It is also unclear how the proposed figure of 40 homes per year is reached as a blend of scenarios 1 and 2. For example, when calculating the completions (54), commitments (198), windfall (62) figures at table 5.5, plus the 220 homes at Loxwood, 25 homes at Plaistow and Ifold, 50 homes at Kirdford, and 75 homes at Wisborough Green, the total amounts to 684 homes over the plan period, or 38 homes per year.

39. Despite this, the Emerging Local Plan (Appendix LPD1, pages 99 and 100) sets out a figure of 40 homes per year over the plan period (679 homes in total), accounting for completions, commitments as of December 2022, windfall, allocation at Loxwood, and non-strategic allocations at Kirdford, Plaistow and Ifold, and Wisborough Green. This is contrary to the results of the Sustainability Appraisal.

40. In a previous meeting with the Advisory Inspector regarding water neutrality (September 2022, Appendix LPD10), the Inspector confirms that, prior to submission of a plan (our emphasis added):
“the Inspectorate can only provide advice based on national planning policy and guidance, along with our own personal experience. While it is possible to explore issues in advisory meetings it is not possible to say definitively that the approaches taken will lead to a sound plan. That’s because ultimately each plan will be considered by an Inspector who has been appointed to carry out an independent examination. In doing so they will consider all the evidence to justify the plan, the representations and what was discussed at the hearing sessions.”

41. It is therefore not sufficient reasoning for the Council to submit the Emerging Local Plan, using a blend of scenarios 1 and 2 that happen to match a 40 homes per year figure in the North of the Plan Area, on the basis of the Advisory Inspector’s commentary in October 2022 (Appendix LPD9), which preceded the issuing of the Water Neutrality Mitigation Study (Appendix LPD6) and the Sustainability Appraisal (Appendix LPD5). One can assume there has been no examination of evidence by the Advisory Inspector, just commentary based on the Council’s own - unsound - narrative.

42. For the above reasons, the Council has therefore not positively prepared or justified the reasons for limiting growth in the North of the Plan Area to 40 homes per year.

Development Plan Infrastructure Panel

43. The Sustainability Appraisal (and commentary at the Special Cabinet and Full Council meetings held on 23 and 24 January 2023) makes references to conversations held and decisions made by the Development Plan Infrastructure Panel. A Freedom of Information request was submitted to request the minutes of these meetings, and the response was that the meetings are confidential and so the minutes would need to be heavily redacted.

44. The transparency of this is in question. While the meetings may not be ‘public' in the sense that the public can attend and watch, the meetings relate to a document that is in the public domain and subject to public consultation, and so there should be transparency into how the decisions and conclusions have been made and justified.

45. In light of the above, proposed Policies S1, H1, and H3 are unsound for not being positively prepared or justified, directing insufficient growth in the North of the Plan Area where there is evidence to support the allocation of additional housing in a more-sustainable way, by including Crouchlands Farm.

Housing Need

Shortfall of supply

46. Proposed Policy H1, Meeting Housing Needs (Appendix LPD1, page 100), is unsound.

47. Paragraph 61 of the National Planning Policy Framework (2021) sets out 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”.

48. The Council’s Housing and Economic Development Needs Assessment (Appendix
LPD2, page 42) identifies a housing need of 763 homes per year based on the Government’s standard method. That figure comprises 125 homes per year for the part of the district in the South Downs National Park and 638 homes per year for the remainder of the district (the plan area). This equates to a total requirement for 11,484 new homes for the plan period of 1 April 2021 to 31 March 2039.

49. Proposed Policy H1, however, sets out the total housing supply of 10,359 homes for the plan period, which equates to 575 homes per year. This is a shortfall in supply of 1,134 homes, or 63 homes per year, against the minimum local housing need as calculated by the Government’s standard method.

50. The Council attempts to justify the proposed shortfall in housing supply due to key constraints in the south (the A27, flood risk, environmental designations) and the north of the district. In the north, the Council identifies key constraints to be the protection of environmental designations, landscape quality, historic environment and settlement character, and water neutrality (Appendix LPD1, paragraph 3.5).

51. We note that this was echoed by the Planning Inspectorate in a Local Plan Advisory Meeting, held on 5 October 2022, who found that:
“The northern area is not constrained by the capacity of the A27 but has its own issues. As a predominantly rural area with limited facilities and public transport, it is not an obvious location for significant development. There are also landscape and historic environment constraints. It is also affected by water neutrality requirements and the potential for capacity issues on the wider highway network. These factors appear to support the Council’s position that a maximum of 600-700 homes could be delivered over the Plan period (or around 40 dpa)”. (Appendix LPD9, paragraph 9).

52. However, that advice was issued prior to the Council’s Sustainability Appraisal (Appendix LPD5) and Water Neutrality Mitigation Strategy (Appendix LPD6) being published, which have since concluded that development of up to 1,796 homes in the North of the Plan Area over the plan period can be sustainably achieved.

53. The Council makes no justification that not meeting its housing need in full would significantly and demonstrably outweigh the benefits of meeting the majority of the shortfall of need in the North of the Plan Area, when assessed against the policies in the National Planning Policy Framework (2021) taken as a whole. The Council entirely overlooks the fact that its objectively assessed housing requirement is not being met. The only reason the Council makes for not meeting its housing need in the North of the Plan Area is set out in a Cabinet Report, dated 23 January 2023, which states:
In the north of the Plan area, previously, given it is less sustainable compared to Chichester and the east-west corridor, the Local Plan has only provided for only limited growth, focused on enabling these communities to continue to sustain local facilities and contribute towards meeting locally generated housing needs, and support for the rural economy, in line with the settlement hierarchy. However, due to the constraint of the A27 in the south of the plan area (see housing section at para 5.34 onwards below), it is considered that this Plan should provide for a moderate level of growth in the north to help to make up the overall shortfall of dwellings, in order to demonstrate that ‘no stone has been left unturned’ in identifying housing supply.

High levels of growth were considered at Loxwood, Kirdford, Wisborough Green and Plaistow and Ifold, but ruled out due to the need to conserve the rural character of the area and its high quality landscape and to minimise the impact on the historic environment. The spatial strategy therefore includes growth at Kirdford (50 dwellings), Wisborough Green (75 dwellings) and Plaistow and Ifold (25 dwellings). Loxwood is the least constrained settlement in the north of the plan area, and benefits from the most services and facilities, including healthcare. Therefore, a moderate amount of growth is appropriate for Loxwood of 220 dwellings, to come forward through the neighbourhood planning process.
The SA of the northern options considered 3 scenarios (plus each scenario with the addition of a potential new settlement at Crouchlands), for low, higher and highest growth. The highest growth scenarios perform poorly and therefore the Local Plan reflects a combination of the low and higher growth scenarios tested, which takes into account the constraints of each settlement and the need to avoid cross boundary traffic and education impacts. A new settlement at Crouchlands has been ruled out as it is not of a sufficient size to be a sustainable new settlement in a rural location and because of the negative impact on the landscape and intrinsic rural character of the area and poor sustainable transport links. (Appendix LPD11, paragraphs 5.19 – 5.21).

54. The Council fails to make a case that the impacts of meeting this need would outweigh the harm cause by not meeting the full housing need, or indeed that impacts of even getting closer to meeting this need would demonstrably outweigh the harm of not meeting housing need.

55. On the contrary, there is evidence to demonstrate that housing supply could be higher by at least 600 homes through the allocation of Crouchlands Farm as a site considered to be suitable, achievable and available by the Council’s Housing and Economic Land Availability Assessment (Appendix LPD7, page 134). The allocation of Crouchlands Farm would be acceptable in water neutrality terms, with both Scenarios 1a and 2a of the Sustainability Appraisal (Appendix LPD5, page 34) delivering new homes below the maximum figure set out in the Water Neutrality Mitigation Report (Appendix LPD6, page VI). Furthermore, there are no heritage and landscape constraints associated with Crouchlands Farm.

56. In addition, the information supporting the applications for Rickman’s Green Village further demonstrate Crouchlands Farm as a highly sustainable site, capable of delivering up to 600 homes alongside a village hub with farm shop, retail and commercial units, office and flexible working space, and open space provision (as well as provision for a primary school or other suitable community facility).

57. Proposed Policy H1 is therefore unsound on the basis that it is not positively prepared or justifiable when accounting for all reasonable alternatives.
Historic under-delivery

58. The previous (adopted) Local Plan (Appendix LPD3, page 49) did not provide a sufficient supply of housing to meet the Council’s full housing need at the time of adoption, which is the same approach proposed by the Council for Policy H1.

59. Many of the sites allocated for housing in the previous (adopted) Local Plan on sites in the south of the District have not been delivered, as demonstrated by Appendix 2, Table E of the Council’s Five Year Housing Land Supply Position Statement (Appendix LPD12). This confirms that four sites allocated by the Council previously, with a combined projected supply of 2,210 homes, have not been started, and do not even benefit from planning permission. We understand that none of those sites has come forward due to impediments resulting from site ownership, which raises questions around the approach taken by the Council in allocating sites for housing in the south in the past, which Policy S1 proposes to use again.

60. The Council’s failing to meet its housing supply historically has also resulted in it now being unable to demonstrate a five year housing land supply and so unable to effectively manage proposals for speculative housing developments. This is reflected in a significant proportion – some 87% – of new housing coming from windfall sites (Appendix LPD4, page 12).

61. In addition, the Council introduced a new Interim Position Statement for Housing (Appendix LPD13) which set out a spatial strategy to allow new development adjacent to settlement boundaries as a way of significantly boosting housing supply (Criterion 1). The Council has not carried this strategy forward into the emerging Local Plan. This is despite the Planning Inspectorate recommending this in a recent appeal decision (Appendix LPD14), stating that the application of Criteria 1 suggested “the Council’s [adopted] spatial strategy may be out of date, as a more permissive approach appears necessary to maintain a five-year housing land supply.” (paragraph 25).

62. Proposed Policies S1 and H1 are therefore unsound as they follow the same approach of the previous (adopted) Local Plan, which has proven to be ineffective and unsustainable, contrary to national policy, and the recommendations of the Planning Inspectorate.

Longer Term Growth Requirements

63. The emerging Local Plan as originally published (Appendix LPD15), prior to the meetings of the Council’s Cabinet and Full Council on 23 and 24 January 2023, respectively, set out “some reservations about whether it will be appropriate in the longer term to continue to rely on existing sources of supply (e.g., urban extensions and urban intensification) indefinitely given the potential for ongoing increased levels of housing needs” (paragraph 5.11).

64. In doing so, it identified that a new settlement of 2,000 – 3,000 dwellings to accommodate potential longer-term growth needs beyond the Plan period (i.e. 2039 onwards) will need to be explored.

65. At the meeting of the Council’s Cabinet, a proposed amendment was agreed to remove the above wording and instead insert:
“Beyond the Plan period additional planned provision for housing will be required. During the course of preparing this Plan, it has become apparent that it may not be appropriate in the longer term to continue to rely completely on sources of supply such as urban extensions and urban intensification”
[…]
“In order to be in a position to update this Local Plan within the next five
years the Council will need to consider future population and household growth. At the same time, the requirement for sufficient homes to house a local workforce without relying on excessive in-commuting to the District’s workplaces will need to be considered. The continual evolution of National Planning Policy also presents challenges as in what national, regional, sub-regional and plan area strategic planning context any future reviews of this plan may be undertaken.” (Appendix LPD1, paragraphs 5.11 – 5.12).

66. Reference is then made to the need to work “bilaterally with neighbouring authorities in seeking to find cross boundary strategic solutions to future growth requirements” (Appendix LPD1, paragraph 5.13).

67. The emerging Local Plan (Appendix LPD1, paragraph 5.14) continues to recognise a need to facilitate the identification of possible new development sites specifically within the Chichester plan area, however solutions to meet that need are not explored fully.

68. The Council states that it would consider sites that (with our commentary in bold):
i) are of a sufficient scale to support potential long-term development needs arising and support the provision of key infrastructure and community facilities – Rickman’s Green Village is of a scale similar to surrounding villages, and will provide all necessary key infrastructure as well as community facilities such as a potential primary school (or other suitable community facility), sports pitches, and shops;
ii) are comprehensively planned in consultation with existing communities and key stakeholders – significant public engagement has been undertaken, including two in-person public consultation events, and pre-application discussions with West Sussex County Council (on transport, and education) and Chichester District Council;
iii) provide for a sustainable, inclusive and cohesive community promoting self-sufficiency and with high levels of sustainable transport connectivity – a new bus service connecting Rickman’s Green Village to Billingshurst is proposed, and onsite infrastructure is provided to promote self-sufficiency;
iv) include on-site measures to avoid and mitigate any significant adverse impacts on nearby protected habitats – extensive ecology surveys and assessments have been undertaken to ensure habitats are protected. For example, 10 – 30 m buffers have been incorporated around Ancient Woodland;
v) provide a mix of uses to meet longer term development needs and contribute towards its distinctive identity – the village hub will provide office spaces, shops, a café, leisure facilities and a potential school or other suitable community facility to meet long term needs of future residents; and
vi) are of a layout and form that avoids coalescence with existing settlements and does not undermine their separate identity; respects the landscape character and conserves and where possible enhances the character, significance and setting of heritage assets – Rickman’s Green Village has been designed to be a new rural village that does not rely on or coalesce with other surrounding villages. The design has been landscape-led and reflects the character of nearby villages, with contemporary features. There are a number of mitigation measures in place to ensure the setting of heritage assets are protected.

69. Proposed Policies S1 and H1 are therefore unsound. The Council acknowledges that there are ways of meeting future housing need, which could include an allocation of Crouchlands Farm, but avoids deploying these now, which is not justified.

Water neutrality

70. Proposed Policies S1, Spatial Development Strategy (Appendix LPD1, page 40 – 41), H1, Meeting Housing Needs (Appendix LPD1, page 100), and H3, Non-Strategic Parish Housing Requirements 2021 – 2039 (Appendix LPD1, page 103) are unsound, and contradictory to proposed Policy NE17, Water Neutrality (Appendix LPD1, page 89)

71. The Council’s Sustainability Appraisal (Appendix LPD5), in assessing the proposed growth scenarios for the North of the Plan Area, states that water neutrality remains a “key constraint to higher growth” (page 40), despite a Mitigation Strategy (Appendix LPD6) having been agreed.
72. That Mitigation Strategy (Appendix LPD6) assumes 1,796 homes being delivered in the North of the Plan Area which the Council’s Sustainability Appraisal (Appendix LPD5, page 16) states:
“immediately serves to indicate that there is no potential to deliver the high growth target figure of 1,854 homes as the (minimum) level of growth that would be necessary in the northeast plan area, were the local plan housing requirement to be set at LHN [local housing need].”
73. Based on the above, the Council should have discounted the highest growth scenarios for the North of the Plan Area in the Sustainability Appraisal Scenarios 3 and 3a, which propose 1,964 and 2,564 homes, respectively for delivering more than 1,796 homes (Appendix LPD5, page 26). Page 26 of the Council’s Sustainability Appraisal (Appendix LPD5) states, however, “On balance, just Scenario 3a [highest growth of the four parishes plus Crouchlands Farm, providing 2,564 homes] is ruled out as unreasonable, on this basis, leaving five reasonable growth scenarios”. The Council provides no further justification for the inclusion of Scenario 3.
74. The Sustainability Appraisal (Appendix LPD5) goes on to state that whilst a Mitigation Strategy has been agreed, it “cannot be implemented until further work has been completed in order to design / set up strategic offsetting schemes. In this light, the proposed strategy of restricting growth somewhat [in the North of the Plan Area] is supported” (page 60).
75. That assessment is at odds, however, with proposed Policy NE17, Water Neutrality (Appendix LPD1, page 89), which states that “Development proposals are not required to utilise the planning authority-led offsetting scheme and may bring forward their own offsetting schemes.”.
76. The Council, therefore, seeks to use water neutrality to limit future growth in the North of the Plan Area, despite proposed Policy NE17 facilitating appropriate development from coming forward, such as that proposed at Crouchlands Farm. Proposed Policies S1, H1 and H3 are unsound for not being positively prepared or justified.

C. CROUCHLANDS FARM

77. Our analysis of the Council’s emerging Local Plan shows that it cannot be found sound as the Council proposes a shortfall of supply against its minimum local housing need where there are no exceptional circumstances to justify this, as well as there being evidence to support additional sites for housing.

78. As a result, the Council should be asked to allocate more sites to help bridge the gap in the extent of its housing shortfall and Crouchlands Farm should be considered the obvious first choice given the deliverability of Rickman’s Green Village, as demonstrated by the Council’s evidence base (Appendix LPD5, page 34, and Appendix LPD7.5, page 134), and the evidence presented below.

For further information, see attached supplementary documents.

I have been studying the latest Local Plan and I find to my horror that CDC has decided to allow 240 new houses in Loxwood.

Nearby areas like Wisborough Green and Kirdford have been allocated considerably less houses.

The problem in Loxwood is that the infrastructure has been neglected.

- Waste and sewage inadequate.
- Public transport non existent. We have to rely on cars or kindly neighbours giving lifts.
- we were promised a local shop to replace the old post-office store.
- the road network is insufficient. Recently we had heavy lorries racing down Spy Lane for a whole week.

Luckily we managed to Stop the Clay Pit. We hope the Loxwood clay pit people don't come back with another plan.

I would expect you to ask the CDC to consider the number of houses the want to build in Loxwood. And more importantly, they deliver the infrastructure improvements.

As a resident of Loxwood I am reacting to the CDC local plan.
This plan contains three untruths which fact indicates bad research on CDC's part.
1.The Transport Statement tells us we are well served. We have one bus per day on only four days a week. Any other busses spotted by your researcher are part of the School Run service.
2. CDC claims there is no issue of capacity with sewage.Southern Water have confirmed there is no extra capacity in the sewage system.
3. Cycle Routes do not exist at present, so the notion that 200 extra houses will provide improvement is nothing less than fanciful.

Another three points of contention -
- We have no shop and the School and Doctor's Surgery are at full capacity.
- Southern Water have highlighted a lack of water capacity.
- This local plan ignores the terms of the Localism Act 2011.

I might expect this sort of roughshop treatment in China or Russia but not in West Sussex.

Removal of policy A15

[RECEIVED LATE]
I am writing to object to parts of Chichester District Council’s local plan which affects the village I live in. My objections relate particularly to Policy A15 and sections 10.66 to 10.77, in Chapter 10 Strategic and Area Based Policies of the plan. this policy would have a damaging impact on the village of Loxwood.

Chichester’s Sustainability Appraisal justifies 220 more houses on top of the 91 already in development or being built This means 311 more houses not 220. The justification is inadequate and the argument for the figure is tenuous at best. Chichester’s own Sustainability Appraisal report highlights the limited opportunity for growth in Loxwood and the negative impact it would have. The plan will not meet Chichester’s Sustainability Appraisal report and it does not help to meet Chichester District councils environmental, economic or social objectives due to a lack of infrastructure a lack of sustainability and being an inappropriate area to redevelop. it does not meet the environmental requirements either.

Chichester have not consulted with Loxwood residents or the Parish council and have shown a lack of due process, an inability to co operate with the village. As such I do not believe it is legally compliant. The local plan does not comply with the Planning and Compulsory Purchase Act 2004 or the Town and Country Planning Regulations 2012. The plan will not enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Loxwood has ceased to qualify as a service village and is not in a sustainable location for more development. The village is already overdeveloped and is straining under the pressure of additional houses. There is no village shop. The post office closed in August 2022 and the village shop closed in September 2022. There is a butchers but it does not provide basic necessities required from a village shop. The local school and the local village surgery are both at capacity and cannot sustain any more housing. In addition the surrounding schools are also all full and the two secondary schools in the area are both full.

The transport system is inadequate and Chichester’s Transport Statement is wrong in saying Loxwood is well served by transport links. There is a very limited bus service (just one bus per day only and only on four days a week). In addition the nearest train station is at Billingshurst and parking here is a nightmare. Should you wish to take the bus, then there is no chance you would be able to commute into London or other towns. The reason being there are no buses to serve it from Loxwood.

In addition the roads are all minor roads and not capable of taking the additional traffic. The risk of accidents will increase as well as pollution. Speeding is already a problem in the village despite numerous promises of traffic calming measures and sadly I doubt anything will be done until a child or person is hit by a car which is inevitable.

Lastly, on transport, I am surprised Chichester say they will improve cycle routes as there are none to improve! To also say that there are lots of buses is comical.

The utilities capacity in the village is at capacity. In particular, the is no more sewerage capacity, wastewater infrastructure and water capacity which has been highlighted by Southern Water and Natural England. The number of power cuts is increasing in the local area as a result of overdevelopment and despite the promises of new infrastructure by developers it never seems to arrive. there is still no shop for example.

The lack of sewage capacity is highlighted by sewage being emptied by tankers at the newly built Nursery Green and Thakeham sites daily. I have to endure horrible smells of excrement when I take my children to school in the morning, when the HGV lorries come to empty the tanks. Should these tanks ever be connected to the actual sewage system foul sewage would escape into the River Lox and flow into South Downs National Park.

There is no requirement to provide appropriate specialist housing needs (such as for older people or self/custom build) as this need has already established by the Thakeham / Stonewater site I have walked around the new estate and many houses lie empty. The reason is there is not need for any more affordable / social housing in the area.

Loxwood is a beautiful village with numerous listed properties, ancient woodland and ancient trees, Chichester’s proposal will kill the aesthetics and character of the village and impacts on the wider landscape character. The Thakeham site has already damaged the views from Merryhills and is not in keeping with the vernacular of the village. We need to protect existing important landscape features and key views, not ruin them even more with more housing. The proposal is not sensitive to the historic village setting in size or location and it does not enhance, protect or complement the natural environment or rural character of the village or surrounding area.

The plans would seriously affect numerous important ecological site including, the South Downs National Park which will be affected by over development impact on water consumption within Sussex North Water supply zone on the Arun valley site. Loxwood sits within 13.5km of the River Arun, which holds the multiple designations of Special Area of Conservation (SAC) and Species Protection Area (SPA). IT also sits within the buffer zones for The Mens and Ebernoe Common SACs. Chiddingfold forest is to the northwest and The SSSI Barberry Bridge Pasture site is by the village. Any development would impact these habitats which are critical for sustaining populations within these sites.

Over development of the village will also destroy habitats for the local wildlife including Great Crested Newts, Slow worms and snakes which I and my neighbours have seen in ours gardens, numerous bat species which are protected including Barbestelle Bats, Mammals including, Dormice and badgers which live in Setts along the hedgerows of the village, rare butterflies and many other rare flora, invertebrates, amphibians, reptiles, mammals and birds on the Sussex notable bird list.

Loxwood is a historic village which sits within an area of outstanding natural beauty and includes numerous national Paths and bridleways as well as the Historic Wey and Arun Canal in close proximity.
Goes against Natural England’s policy on water neutrality and their other policies to protect the countryside.

Lastly, there more harm than the public benefit, derived from CDC’s proposals for the village which is in danger of being overdeveloped without the infrastructure to support it. Worst of all, a number of public footpaths would be affected by the additional housing. The degradation of local footpaths will have an effect on the mental wellbeing of residents who use these paths.

I hope that Chichester District council reconsiders its plans under policy A15 and removes this potential travesty. Their own report says it is not a suitable site and is only under consideration because of the lack of options available. But in reality, I would hope Chichester if required go back to the Planning inspectorate and make the case that even if they are required to hit an arbitrary housing figure, if there are not enough suitable sites to achieve this then it has to be accepted. It would be highly irresponsible to build somewhere just for the sake of hitting a target especially if the area is wholly unsuitable.

[RECEIVED LATE]

We wish to object to the Local Plan for the following reasons:-

There is a total lack of infrastructure in Loxwood. We have no village
shop, virtually no bus service, and no train station that you do not
need to drive to.
Loxwood Primary School is at capacity, as are, as far as I am aware, the
next nearest schools out of the catchment area (Wisborough Green,
Plaistow & Kirdford, Rudgwick Primary schools). If 220 houses were
built, that's likely to bring several hundred school-aged children
needing primary and secondary school places, which will not be available.
An additional 220 houses would also bring 220-400+ cars to the village,
resulting in further traffic issues and pollution (Station Road is near
impossible to drive down at school pickup and drop off times due to the
excessive number of vehicles using it for parking).
Loxwood Medical Practice is at capacity. Just trying to phone the
surgery in the morning would highlight how stretched they are. The
surgery could not cope with the several hundred new patients from
Loxwood alone.
Lack of sewerage capacity - We were told 10 or so years ago that the
sewer system would not cope with the additional houses planned for the
land by Farm Close/Loxwood Surgery. The sewer system has not been
upgraded, yet there have been two larger developments, as well as a
couple of smaller developments which have been built since.
The village flooded quite badly in December 2013, with the Onslow Arms
having to be completely refurbished and residents of Burley Close having
to be evacuated from their homes. Only one route out of the village was
just about passable. Additional homes in the area would have an impact
on where this water could go if similar happened in the future,
potentially causing even more properties to be affected by flooding.
Wildlife habitats would be destroyed causing further decline in numbers
of already protected species.

We strongly urge you to vote against this Local Plan.

[RECEIVED LATE]

I am sending to you my objection comments to Chichester Local Plan in respect to Policy A15 Loxwood . This essentially details the plan to build a further 200+ houses in the rural community. Permission has already been granted for 90+ houses, so the new proposal is in addition to this. Please can you ensure my objection comments are submitted .

I am sending this to you as I have been unable to submit my application via the portal. I wonder if this is because I was trying to access this using an iPad? Unfortunately I did not have access to my desk top until after 5pm by which time it appears the option to comment has been removed.

I object to the Policy A15 for the following reasons:

1) Loxwood is a rural village setting with limited infrastructure. The policy refers to developing the existing public transport and Loxwood is well served by transport links. That is totally incorrect . The current bus service is extremely limited only one bus a day on 4 days a week. Clearly for anyone who currently lives in Loxwood, to access employment, social, education, food provision it is a necessity to have a car to access the local towns Billingshurst and Cranleigh which are 5 miles away.

It is unrealistic to suggest the current service can or will be improved to make this viable for the community to be able to access schools/work in neighbouring towns.

2) The nearest train station in Billingshurst is 5 miles away and has minimal parking . There is no public transport to the station so anyone using train routes need their own means to get there. Should 200+ houses be built in Loxwood that is a huge increase in vehicles using the local rural roads.

3) Loxwood has been referred to as a service village. I challenge this as there is no local shop. In previous housing developments a shop was “agreed/promised” . This has not materialised.

4) Employment in this rural community is limited. To access employment in local towns anyone would need to use a car . The local rural roads would not be able to sustain this increased traffic use safely.

5) I am concerned about flooding in this area should future building take place. I have personally experienced my house being flooded in 2013. Increasing building in my view would put pressure on the water flow and further risk of flooding.

6) The sewage system is at capacity . Further housing development would be detrimental to the existing systems.

7) I am concerned about power in the community and internet broadband connections. This is already poor. We do experience power cuts and lack of internet band width. With further housing development the existing facility, will be even more over loaded.

8) I am concerned about education facilities . There is a local primary school, which is at capacity. The secondary school in catchment is over subscribed. It is not clear in any plans whether any provision is being made for this . Building 200+ houses in this community would increase the demand for education. The current provision would not be able to provide a service.

9) Loxwood has had a neighbourhood housing plan, which it appears has been completely ignored by the planning authority in recent planning applications. It is my opinion Loxwood has already, taken more than its fair share of new housing in the County. I remind you again that this is a rural village with limited infrastructure.

10) I am concerned about the impact on the environment with a proposal to build a further 200+ houses, in what is a village within an area of natural beauty.

11) This proposed development has no benefit to the local community and would lead to over development of the village.

Kind regards

Sue Bennett

[RECEIVED LATE]

Objection to Policy A15 CDC plan to allocate land for development of additional 220 dwellings in Loxwood
(sending this by email as had problems registering my objection on the website)
I object to the A15 CDC plan as:
Loxwood has a distinct lack of appropriate infrastructure to serve extra housing, such as no post office and the village shop closed in 2022.
Loxwood is very poorly served by transport links, there is only a bus service on 4 days a week, and even then, only 1 per day.
Future developments could cause an increased flood risk to existing properties, by there being less undeveloped land to soak up heavy rainfall, the run off from hard standing areas causing further problems. This is unacceptable.
Southern Water have stated that there is no capacity for extra sewage in the existing system from additional housing in the village.
Any sewage overflows into the local streams and river, as a result of this lack of capacity, would create an unacceptable biohazard for local residents, as well as local wildlife.
Local habitats for wildlife will be compromised by over-development of housing in Loxwood. I believe the addition of a further 220 new houses would constitute over-development.

[RECEIVED LATE]

I am objecting to further development in the village at Loxwood. Your system for correctly making objections is too complicated to follow so I am hoping this e mail will be submitted as an objection.
Our sewerage system is not suitable and will not accommodate more dwellings, our infrastructure is not adequate to sustain a larger population.
We do not have a shop or post office, there are no buses running regularly, our bus stop is being used as a car park.
It is impossible to get an appointment at our doctor’s surgery.
I am objecting to all developments which has been tabled for Loxwood and any future development which may be applied for.

[RECEIVED LATE]

We have been unable to access the consultation form online but we understand that we can send our comments via this email address.

We would like to add our concerns regarding the additional housing which has been allocated to this area. Enlarging these beautiful villages will significantly alter the character of the local area. There is almost no public transport to these villages and the surgery at Loxwood is already under pressure. The environmental impact of building more houses in an area of natural beauty would also be significant. It is not clear how much consideration has been given to infrastructure requirements - schools, employment, transport.

Once these beautiful villages are expanded and developed there is no going back and they are lost forever along with the attendant reduction in quality of life for the people who live there.

[RECEIVED LATE]

I object to the quantity of properties proposed in the Local Plan on the following grounds:

Ecological impact:
The increased noise, light pollution and traffic will impact negatively on the biodiversity of the area as fragile local animal habitats are destroyed. Rare species of bats, barn owls, deer, butterflies, badgers and countless other animals benefit from the rural environment. Once this tranquil location is disturbed the ecology of the area will suffer beyond repair.

Traffic:
Loxwood district and the surrounding roads are very quiet with many farms and stables in the immediate vicinity. Horse riders, dog walkers, hikers and cyclists frequent this location and the additional traffic associated with the provision of the proposed number of properties would severely impact upon this beautiful rural area, and the safety of its residents.

Due to the rural location there is very limited public transport in this area meaning that new residents in the proposed developments will need to travel in private vehicles.


Infrastructure:
Existing residents are struggling to obtain medical appointments and to secure school places already without exacerbating these issues by increasing the permanent population.
There are also the concerns around water neutrality and the depletion of this valuable resource. This Northern more rural parts of the district are struggling with this already without increasing the strain by the addition of further developments.

[RECEIVED LATE]

We are writing to lodge our deep concern regarding the most recent proposed plans for development within our Village of Loxwood . Already there has been a lot of new housing developments within Loxwood and we can see more springing up at present. We are very opposed to this overdevelopment which is eating into the countryside and affecting our Community . The proposed development in question is going to take over farmers fields and is going to ruin the environment for all concerned - farmers and local residents alike. With the recent emphasis on food production within the UK due to the dreadful war in Ukraine and the knock on effect to food production in Europe, we would have thought the emphasis would have been on home grown produce from now on. This means farmland not development for housing. We are aware that the proposed development does not meet environmental requirements either.

Loxwood does not qualify as a service village and is not in a sustainable location. We no longer have a village shop and post office. They closed in August/September 2022. There is a lack of infrastructure such as a limited bus service and the closest train station is over 6 miles away. The local school and surgery are already at capacity and cannot sustain more housing. There is also a lack of sewerage capacity in the area and Southern Water have confirmed this but Chichester Borough Council have denied there is a lack of capacity. There is no wastewater infrastructure either to support the plans. There is also a lack of grid capacity and power cuts are increasing in the local area due to over development.

We feel that the site would be inappropriate It would destroy important habitats which Chichester Borough Council says need to be retained! The plan cannot integrate this housing or mitigate any impacts on the wider landscape character as a result. Important landscape features and key views would be affected from numerous Public Rights of Way both to the East and West of the Village.

Lastly, we have been made aware that the proposed plan is not consistent with National Policy and will not enable delivery of sustainable development.

[RECEIVED LATE]

I would like to register my strong objections to the Local Plan published on 3rd February last, which sets out proposals to develop 220 new homes in Loxwood in addition to the 91 that are under development.

My principle cause for concern about these plans are that it is already demonstrably clear that the infrastructure in Loxwood cannot adequately support the existing developments, let alone this proposal, which contains no mention of any attempts to improve it.

This includes but is not limited to:-

Water & Sewerage: Southern Water have admitted that the capacity in Loxwood is insufficient to deal with even current demand and has no plans to increase it.
I have personally experienced sewage backflow on my property on a number of occasions in the last twelve months, which has been rectified recently by the fitting of a valve system which shifts the problem elsewhere. Furthermore, the “workarounds” in place for recent housing developments lead to unpleasant odours and risk of discharge into the water courses.

Services: Loxwood has no village shop, its school and medical practice are at capacity and there is negligible public transport serving the village. Over development is placing a strain on the electrical grid supply leading to instances of power disruption.

Landscape and flood risk: The conversion of the significant amount of land involved with this proposal from fields to housing plots will add further pressure from rain water flow on the capacity of the River Lox and Loxwood stream, thereby increasing the risk of flooding to many properties (including my own) in the village.

The proposals dig deep into the natural environment that defines the character of the village and its surroundings with footpaths, vistas and natural habitats permanently degraded as a consequence.


Loxwood PC developed a Neighbourhood Plan in 2018 which was revised in 2020; this seems to have been ignored completely by CDC despite central government encouragement of such plans. It appears that CDC’s desire to focus more housing development in the North of its district is leading to draconian disregard for the considered views of local residents reflected in the Neighbourhood Plan.

I ask that you take my points into consideration when this Local Plan Proposal is refined further.

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

It needs to be revisited and this madness stop!

A15 - Loxwood. The number of proposed additional houses for Loxwood is incredible! The village has already taken it's overloaded unfair share already and to want to add and develop a further 220 is abhorrent. There are NO facilities to support this influx of houses/people and is detrimental to the current residents.

These additional homes need to be cited close or in an urban area where there are sustainable transport options available and a functioning sewage system which overflows whenever there is heavy rain. If additional houses are required the total should be massively [reduced]. Also the date from which new applications count towards numbers should include the 50 council/housing association properties built off Pond Copse Lane. Scandalous that these have not been included in any housing numbers

Adding an additional 220 homes to Loxwood is not sustainable. This is a rural location with absolutely nothing by way of public transport. The village does not even have a shop at the moment.

The village has dutifully supported enlargement through its now 2 Neighbourhood Plans, and now you want to turn the village in to a small town by making the village take an additional 220 dwellings. The sewage system cannot cope at the moment let alone adding hundreds more.

It would be better to build near to major roads. Our little B roads are not suitable and it would render the current village unsafe to add more new traffic, with cars, delivery vans and supply vehicles.

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
Loxwood floods badly
The sewers are too small to cope with the village as it now is
Fresh water supplies are stretched to the maximum as it now is
Water neutrality is an ongoing issue in Loxwood
There is no gas
There is no shop
There is no public transport
We are car-dependent and building 220 new homes would bring huge air and traffic pollution

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

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

I am concerned there was a lack of transparency on this plan, as a resident of Loxwood I was unaware until the day before deadline. Plan shows Loxwood will significantly increase in size, merging with other surrounding villages such as Ifold, Alfold and Dunsfold to end up being a town and will lose its village character. There is severe lack of infrastructure. The A281 is a single lane road and is constantly jammed at the Bramley and Shalford junctions, due to high traffic and roadworks. It is 12 miles to Guilford and Horsham stations, so difficult is anyone needs to commute, the only option is to drive. There is only one shop and that is closing. The post office has already closed. There is only one surgery and it is near on impossible to get a doctors appointment in 1-2 days. Water, and sewage and electricity capacity is a major concern. There is only one primary school with limited places so children will have to travel away to go to school.

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

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

The housing allocation for Loxwood should be moved to locations better served by services, employment, public transport and available utilities.

I object to the significant allocation of housing to Loxwood as development is in an area remote from employment and services, not well served by public transport, not within cycling distance of services and employment and will increase pressure on already overloaded utilities, particularly sewage.

The number of houses needs to be reduced.

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

There needs to be reduction in the number of houses required in Loxwood back to the numbers stated in the neighbourhood plan which is currently held up in CDC.

The plan for Loxwood is unsustainable given the local lack of employment, public transport and waste water disposal. There will be a total reliance on car journeys for work, leisure and living needs. For these reasons the increase of 220 houses is fundamentally flawed and unsustainable. This local plan demonstrates a lack of understanding of the environment in the far north of the district and needs revisiting for Loxwood and surrounding villages.

Plan is totally unsuitable for Loxwood and should not expand the existing planned sites in the LDP.

Plan does not comply with current and future government strategies, bear no relation to infrastructure of Loxwood ignoring lack of transport via public services, one bus per day, four days per week, limited employment, resulting in increase in car transport to work either to Guildford, Billingshurst, Horsham. 1 village school, GP practice at capacity no room for expansion. Lack of sewage capacity already resulting in private sewage for 2 new housing estates. Environment totally ignored, wildlife corridors destroyed, no protection of current wildlife habitats and degradation of existing bridleways and footpaths