Meeting Housing Needs

I do not support Chichester taking on any of the South Downs national park housing allocation

Try as I might I cant find the Chichester Housing and Economic Development Needs Assessment (HEDNA). The need for affordable housing is undeniable but I am sure it relies on a central government formula that takes no account of local conditions. Anecdotal evidence, some from people who work for the current developers, report that as much as 40% of the CURRENT new homes under construction are being sold as second homes. And still you want to build more on the Western Manhood Peninsula?

Recent broadsheet reports indicate that indigenous populations in the west and other countries around the world are stagnating and in some cases declining. The main driver for UK population increase appears to be from immigration. Given that immigration may now be better controlled the question is who is all this housing for? Few object to affordable housing for local people but it appears that Developers do not like building starter homes as there is a much smaller profit margin for them. We could also end up with another fiasco like Skylark Gardens in Hambrook where most people realised that the houses would not be sold privately because of the electricity pylons and they appear to have been sold to a Housing Association who may not be concerned about their occupants health. We also have the situation, despite Government reassurance that new houses would not be built in back gardens, where Hambrook appears to be exempt from this rule. So much for all the work done on the Neighbourhood Plan. To cater for another five hundred houses in Chidham and Hambrook, despite the already large number recently built, will no doubt require the use of Greenfield sites, again despite yet another pledge to the contrary made by the Government. It is therefore very hard to understand and justify the need to completely urbanise a once semi-rural and picturesque area.

I object to the proposed building planned in manhood peninsula near Donnington. This will have a hugely negative effect on the local area concerning traffic, which is already very bad. The proposed idea to not be able to turn right at the Stockbridge area would be detrimental to local residents. And I don't see how it would help the traffic situation. The planned road building works would cause huge disruption. The area North of Chichester should be considered instead as this would have much less impact on existing residents and would not further add the the traffic on the A27.

Resident, Donnington Parish.
The settlement strategy focuses predominantly on the East-West corridor which is closely aligned with the route of the A27 running to the south of Chichester. Given the severe congestion and delays currently on this route, to have considerable additional traffic generated by these proposed developments at these sites will severely exacerbate the situation.
Also future road improvement plans which may be proposed by Highways England are not factored in.

Resident of West Wittering
Comparing the ONS Population Data with GL Hearn OAN there is no correlation. It is also noted that GL Hearn stated an OAN for the District of 775. Take off the SDNP OAN of 125 this leaves the Plan Area at 650. There is no capping.

Attached is a comparison between ONS based estimate and GL Hearn

1. This plan is based on a figure of 609 houses per year, an uplift of 40% on the current annual delivery, which is the maximum allowed, as Chichester District Council have an Adopted Local Plan. If an Adopted Local Plan had not been in place the HEDNA (GL Hearn) calculates the District increase in housing for demographic growth to be 517 houses p.a, based on the 2014 Household Projections. This figure includes the South Downs National Park. There has been an updated 2016 based Household Projection, which decreases the forecast housing required nationwide over the next 25 years by 24%. This means that the latest available household growth projection growth over the plan period is likely to be in the order of 392 houses p.a. The South Downs National Park are planning to supply 84, leaving 308 needed for demographic growth in the Plan area. Even adding the ridiculous 51.5% multiplier for earning/house price ratio still only gets to 466 houses per year. It is most unlikely that 609 houses are going to be needed every year until 2035. The Plan should be more realistic and reflect this fact.

CDC, whilst noting and complying with the duty to co-operate, should insist SDNP accept its allocation of 41 homes per annum. Without some provision for additional housing the communities located in the park will not thrive. Their facilities such as small schools/shops/doctors facilities will be lost to them as resident numbers decline.

Housing allocation was specifically front loaded during the current Local Plan period to allow for infrastructure developments across the district and it is unfair to ask the Manhood Peninsula/Donnington to take a number on this scale given its allocations under the new plan.

Paragraph 4.2.2 states that Chichester is meeting the unmet need of the SDNP, however the national park should fulfil its allocation to ensure the communities there have sufficient affordable housing and growth to thrive. By adopting this unmet need, development is being squeezed into an increasingly smaller area of Chichester between the sea and the national park; the SDNP has sufficient land capacity to accommodate this development sympathetically and has a duty to support its rural communities.

No justification is presented for the requirement to accommodate the unmet needs of the South Downs National Park, at the expense of an area already constrained by the need to protect the Chichester Harbour ANOB and the Pagham Harbour SPA

A number of land "parcels" (Sites) have been removed as apparently unsuitable yet a number of other have been retained or substituted, which have in some cases more reason for removal. ie Westerton Farm, North of Maudlin Farm, around Westerton House, South of Stane St all of which are detached from settlement boundaries. In addition land around Goodwood ie east and west of Rolls Royce and land underneath the flight path,which is a non valid CAA reason to not have housing/manufacturing development.

It is important that the South Downs National Park take its allocation of 41 dwellings per annum. Social housing in particular is required if communities are to thrive.

There is no mention (that I can find) in any of policies S4, S5, or S6, or anywhere else in the plan, of two imperatives in the District's provision of housing:
1. the need to ensure that the housing provision proposed meets the needs first and foremost of local people with a provable link to the District of a family or employment nature (and especially public-service employment such as teachers, police and health-workers), before it is made available to the wider housing market in the SE of England. What we need is local houses for local people, and in particular local houses for the next generation of local people emerging from university or job-training and desiring to set up home in their home area.

2.A way to inhibit the purchase of housing in this tourist area for use a second home, for people who are actually and normally resident elsewhere, e.g. London. There is no mention made, for instance, of any proposal to impose punitive council tax on residential properties which are only in occupation for a small number of weeks of the year. Other Council Authorities in tourist areas where this has become a real blight, and made it impossible for young, local people to set up home in their local area, have taken steps to control this. Chichester should do the same.

TheSouth Downs National Park should take it's allocation of 41 dwellings per annum- without some low level development in the Park, particularly social housing, communities there will not thrive

Whilst the District Council is the housing authority for the whole district it is accepting the National Park's housing allocation to be bullt outside of the National Park. This will mean that there will be no affordable housing provision made for local people growing up in villages within the Natiomal Park. This will turn the park into a museum full of expensive and second home housing which will ensure the communities whither and die as some National Parks have been finding to their cost.

I don't agree that the housing allowance should include "an allowance for accommodating unmet need arising from the Chichester District part of the South Downs National Park". I fail to understand the reasoning behind this.

4.22
Are we meeting housing needs or delivering a government policy that we have no control over? Is this demand led? Do we need this level of housing here? Not proven. We accept we need more housing especially for our young but this policy fails to create a coherent plan that will satisfy local people.

Section 4.5 states "It is recognised that growth in both urban and rural areas is required to meet the changing needs of the area's population." Growth in the SDNP is required and therefore the acceptance of 41 homes per annum should be overturned and the allocation sent back to SDNP within our area for them to consider and incorporate in their plan.

Primary schools in the SDNP are undersubscribed and development to the North is appropriate to meet housing need but also to maintain local viable public services such as school PANs. There is a need to sustain rural communities but whilst mentioned as a priority I can see nothing that addresses these needs in this plan.

4.22 states " This reflects the identified objectively assessed housing needs of the plan area, plus an allowance for accommodating unmet need arising from the Chichester District part of the South Downs National Park." I do not believe that we should be accepting 41 homes a year from the SDNP in the life of this plan. The agreement between CDC and SDNP needs to be revisited and the allocation handed back to SDNP. We will not affect their overall numbers and will ensure that they meet the needs of their rural communities and this allocation could easily be met within their plan. This then would reduce the number of strategic sites we need to identify. It will also ensure that the public facilities can be maintained within their communities and reduce the need to increase schools in the city and to the south certainly in primary and infant settings.

The section states" It is recognised that growth in both urban and rural areas is required to meet the changing needs of the area's population." Growth in the SDNP is required and therefore the acceptance of 41 homes per annum should be overturned and the allocation sent back to SDNP within our area for them to consider and incorporate in their plan. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

Resident, Donnington Parish.
The proposals contained under AL6 are an attempt to re-instate by the back door elements of Option 2 ( the Stockbridge Link Road) and Option 3A ( no right turns at the Stockbridge roundabout on the A27) of the Chichester Bypass Improvement Scheme. Both these options were rejected then at the consultation stage and are no more acceptable now.
There are a number of specific points I would like to make in support of my objections to the proposals contained in the Local Plan Review:

● Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
● Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
● Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
● Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
● Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
● The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
● There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
● Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
● Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
● A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)
As well as the above points which directly and negatively impact on Donnington residents and with reference to the proposals contained in AL6:
There is currently no direct access from the area delineated by AL6 and Chichester City Centre over the A27 or any proposals in the Plan for such a direct route. The traffic generated under AL6 proposals will add considerably to existing severe congestion and delays on the existing the A27.
The AL6 proposals do not seem to have been considered with reference to any future road improvement schemes proposed by Highways England. As the A27 is a strategic route, the effect of the proposals under AL6 will inevitably impact on future HE plans concerning on- line improvements to this route. No consultation with HE seems to have been considered or taken place concerning this critical area and the effect on traffic flows, pollution, delays to local traffic etc.

Full detailed submission for the Local Plan and supporting evidence is attached.

The representations attached to this submission reflect a high level summary of the detailed submission and do not contain the full level of detail received.

High level comments received:

a. The transport study conducted by Peter Brett Associates (PBA) is not fit for purpose and needs to be rewritten. The scope set for PBA is far too constraining and counters the democratic process agreed by the council to seek alternative routes.

b. Many of the documents are inconsistent and in their current form smack of inconsistency and bias. Reasons for excluding some strategic sites are not consistently used for other sites.

c. Many of the evidence documents are not present or are not complete for this consultation. These will need to be re consulted when they are complete.

d. CDC should not be accepting the unmet housing need from the South Downs National Park (SDNP). They should also be going back to government to insist that until certainty is provided on the A27 this area can not accommodate future housing and or employment space.

e. The proposed link road was resoundly rejected last time it was proposed by Highways England. CDC need to respect the voices that rejected what is option 2 by stealth. Particularly as the PBA report states that the building of the link road will offer other "strategic options". This will not be tolerated locally.

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The Goodwood Estates Ltd welcomes the opportunity to again participating in shaping the future of the District through this review of the local plan. The authority will be well aware of the Estate's firm view on the future scale, shape and form of Chichester to ensure that it retains the very special characteristics that underlie its economic success.

Development to meet the growing needs of the City and its environs must be accommodated if the District is to prosper and grow, but this should not mean a "free-hand" for developers on each and every undeveloped 'greenfield' around the City. Development of the next area of undeveloped land adjacent to the city's existing boundaries does not mean it is the most sustainable approach for the community as a whole. It is all too easy for landowners, at a time of acute housing demand, to promote sites as the next closest to available services (often 'as the crow flies') providing housing quickly to meet that undeniable need. The north and north-eastern edges of the city are vulnerable in this regard, an area for which the maintenance of openness is essential for the sustainable and sound interrelationship of Chichester with the neighbouring national park.

Up and down the country, the negative effects of suburban housing growth promoted on that basis are experienced; often without a true recognition of infrastructure needs and a consequential increase in car borne journeys and loss of greenspace. Equally the often, bland design and over-developed sub-urban layouts, tacked on to urban edges, may mathematically meet local needs and offer people an opportunity to own or rent a home, but consequentially erode the community and character of locations to the long-term detriment of its economic base, identity and community distinctiveness; this is particularly true of cities such as Chichester, where the overall character and ambience underpins much of its economic success.

The authority will be well aware of the "Cathedral Cities Initiative", which seeks to recognise the economic and heritage importance of protecting the form and context of the country's important cathedral cities and historic market towns. By providing clear, precise and 'joined up' planning policy protection, that directs new development and associated infrastructure appropriately to sites best able to accommodate it in terms of benefits to the community as a whole (offering benefits in excess of the provision of additional homes and not just the individual interests of the landowner 'dressed up' as offering wider local benefit) it will prevent inappropriate inner-urban and sub-urban development that will cumulatively destroy the true character and distinctiveness of the city.

Chichester is used as an exemplar in the Cathedral Cities initiative, promoted initially at the time of formulating the last local plan for the District, where there was a real threat unchecked urban expansion would undermine the very essence of the District's local economy. That threat has been reduced through this local plan by changes to strategic allocations, but the threat remains from unscrupulous developers and landowners who will continue to exploit the 'loop hole' provided by a lack of housing supply or incomplete planning policy position (potentially an acute situation until this plan is adopted). It is essential this plan not only makes provision to meet objectively assessed housing and employment needs but equally ensures that essential open areas, around and within the city, which contribute positively to its setting, character and economic vitality are given long-term protection through specific policy designation.

The NPPF is explicit that sustainability is a true balance of social, economic and environmental considerations. This means the plan must represent a true reflection of the suitability of a location to accommodate additional growth in a meaningful way. It must not apply the over simplified, developer led approach that the next piece of available land nearest the centre must be sustainable and developed for housing. A robust strategy will look at all sites within the district making use of all appropriate and available land within urban areas, surrounding settlements and along transport corridors, as well as the "easy pickings" on the urban edges. Development sites further from the city centre ,can often prove more sustainable in terms of the NPPF sustainability balance than sites that comprise the next undeveloped site on the urban edge. Any development promoted must, as a minimum, ensure that it demonstrates a positive response to the sustainability balance, not just meeting a mathematical housing need, and provide appropriately, not only for the infrastructure needs of the housing to be provided , but also for the community as a whole; too many development proposals focus simply on the needs of the individual site giving rise to the many real concerns of local people that the community does not have the capacity to absorb additional housing.

The Estate is therefore heartened to see the council taking a bold step through this Local Plan Review to reconsider previous development scenarios, while ensuring that a true level of housing need is accommodated. Paragraphs 4.30 to 4.33 recognise it is not sustainable to continue to rely on past sources of supply. We support this stance fully and encourage the council to take the initiative forward even at this early stage. As stated in the draft plan, there is a long lead in time to such a fundamental and complex change of direction in strategic development, but without a meaningful start now old habits will continue, resulting in an increasing unsustainable City and loss of the very factors that undermine its economic success. There is an inevitability that developers and landowners affected by the changes, will, through planning applications and appeals, do their utmost to ensure their individual interests are protected, over and above the long-term impacts of inappropriate developments on the community as a whole. To counter such proposals in the short term, this plan must set out a logical, precise and robust strategy that follows all up to date Government advice in a positive and sustainable manner

The Estate believes a sound planning strategy set out in this local plan review can deliver ample development land within the district in a manner that will meet housing and employment needs while protecting the very important transitional relationship offered by land between the urban edge and the SDNP boundary. This will involve a step change from past trends of allocating the next area of land as development locations, to be focussed more on evolving settlement hubs on good transport routes, such as around Tangmere, and allowing appropriate scales of development to sustain rural settlements that have to date be excluded from growth considerations. This will involve an on-going dialogue with adjoining authorities under the duty to co-operate to ensure future development is located in sustainable locations where it is most appropriate and not simply in locations of least (often political or subjective) resistance. The Estate will support the council in its emerging strategy and looks forward to working alongside it in the pursuit of a sustainable social, economic and environmental future.

The district is both fortunate but equally unfortunate to have a large part of its area within the National Park, a similarity it shares with the Estate. The purpose and objectives of the Park are acknowledged and supported, and the Estate continues to work with SDNP to establish a planning regime that recognises the true role of landed estates in establishing the character and form of the National Park. This includes the generation of planning policy and proposals through the emerging National Park Local Plan, that recognise the importance of allowing estates to continue to evolve such that the character of the National Park can be sustained. This includes an appropriate planning approach that allows justified estate development, which may at times appear 'at odds' with general national park objectives.

It is the Estate's belief the Park has not considered the true development capacity of its area and this will have unintended consequences on communities, not only within the Park itself, but also within surrounding districts. If the Park is to avoid development up to its boundary, in part a response to its own displaced needs, it is important the District retains existing open land to the north and north east of the city, permitting only new development and activity that are appropriate to a rural area, complement existing land uses and or which maintain the essential openness of the area.

Land between the city and National Park is an area that must be governed by landscape priorities that provide a crucial open, and where deliverable, accessible green space to the city community, but equally provides
(a) clear linkages to the national park,
(b) protects the integrity of the National Park boundary, and
(c) protects the important relationship and setting of city and Park.
Definition of the City Boundary (Plan SB1) should not simply be a red line on a plan, but supported by clear policies and proposals to encourage the boundary to be enhanced and defended.

The Estate owns a significant "buffer" area between the National Park and City (Goodwood Estate Plan 1) and will continue to work closely with both the Council and the SDNPA to achieve such an objective; to establish an appropriate planning policy regime for land between the city edge and National Park. A sound planning approach to the use of land south of Lavant Straight, between the A285 and A286, will ensure policy objectives within that area are complementary, and do not detract from the setting of either the historic city or national park. The land should be kept open primarily with the exception of appropriate development around the settlements of Westhampnett, Westerton, Strettington, and at Goodwood Aerodrome and Motor Circuit (as more specifically controlled through other policies of the plan). The land should be used for agriculture, countryside, forestry, public access and other landscape purposes.

Through representations to this local plan, set out in individual comments to policies and sections, the Estate seeks to demonstrate its commitment to the future sustainability of Chichester and its community through appropriate use of this "buffer area."

New policies proposed through the Local Plan, such as those proposed for the Goodwood Motor Circuit and Aerodrome, provide a positive response to the above objectives and are to be supported. Provision of a "Whole Estate Plan" for Goodwood as required by policies contained in the emerging National Park Local Plan, will provide a planning policy context that straddles the District/National Park boundary. The District Local Plan should acknowledge this approach and ensure that its policies do not conflict.