Policy S5: Parish Housing Requirements 2016-2035

The apportionment of housing is not balanced.
Loxwood (125) versus Kirdford (0), Wisborough Green (25) and Plaistow/Ifold (0).
125 of the 500 proposed total is 25%. How can that assigned apportion/ratio for Loxwood be classed as fair? Loxwood has already taken on c.60 new builds
The roads, school and doctors surgery will not be able to cope with such an increase. PLUS with the development just up the road in Alfold Surrey, this adds even more 'weight' into/onto Loxwood village and it's resources. The roads are busy enough with speeding vehicles at all hours.

I would like to put forward my objections to the above plan.

I have lived in Loxwood for six years, and took part in the consultations for the original village Neighbourhood Plan.
The village fought, and won, an appeal for extra houses not to be built, apart from the original acceptance for 17 (now 19) houses to be built on land south of Farm Close. (17/02370/FUL). These have yet to materialise.
Now residents have been told that we should accept another proposed 125 dwellings on areas within the village boundary. I would like to protest on the following grounds:
1. The village is already susceptible to flooding from surface water and sewerage. Last occasion May 2018. We are told that flooding is a once in a hundred years probability. How is it that the village has seen flooding at least three times in the last six years? Ever heard of global warming?
a) Some houses have their sewerage manhole covers welded shut to prevent the escape of noxious fluids escaping onto the property. The Loxwood stream is, in effect, a main drain for the community.
b) New areas targeted for housing are all uphill from the majority of the village housing. As water flows downhill this does not bode well.
c) Overflow tanks are built under land south of Farm Close in order to relieve pressure on the sewerage system as necessary.
d) More overflow tanks have recently had to be reinstalled beside the main road through the village to cope with sewerage from the new Loxwood Green housing site.
e) The diameter of the sewerage pipe under Spy Lane was designed for the amount of housing in the village many years ago. It urgently needs upgrading/replacing. However, Southern Water have no plans in the next ten plus years to do the work. With so many additional proposed properties it stands to simple logic that the present system will not be able to cope.
f) One of the problems holding up the new Farm Close site I believe is that the sewerage problem has so far been insurmountable in relation to costings.
2. The village school is already at full. No plans have been made to increase capacity.
3. Transport - the village is very poorly served by public transport. A major problem for residents without the ability to drive.
4. The Loxwood Medical Centre will be over subscribed. For anyone requiring medical attention elsewhere transport is a major issue.
5. The main road through the village is very busy, especially at peak periods, whilst safety, especially in the vicinity of the few shops and Loxwood Green is poor. There are no crossing points for pedestrians. This problem will be exacerbated with the building of further housing. Parking is already hazardous.
6. There is little employment in the village, thus most who work need to use private transport. Further housing would increase this.
7. The village has some social housing and with more planned within further developments and high transport costs, younger people will seek housing and employment nearer the towns or further away. With train fares ever increasing, together with the cost and lack of sufficient parking in Guildford, Billingshurst and Horsham, commuting is unattractive. Thus the community is most likely to only attract older people.
8. With so much new housing built and planned around the Alfold, Dunsfold and Cranleigh areas the B2133, already a nightmare to drive on to and from Guildford in the rush hour, traffic will slow to a crawl. (It already does through Bramley and Shalford at these periods.)
9. Whilst a new Co-op store was promised on Loxwood Green there is still no sight of a beginning.
10. The village hall is very well used. Capacity may be insufficient if the size of the village is increased.
For the above reasons I feel that to burden Loxwood with the proposed additional house numbers is disproportionate and unfair, especially when looked at in relation to the very small number of proposed dwellings in neighbouring villages.
The Draft Local Plan acknowledges that Loxwood has no sustainable public transport links.
The Draft Local Plan housing provision for Loxwood does not meet the test for sustainability and this has to be considered to be unsound.

I am a little perturbed by the plans for an additional 120 or so homes planned for Loxwood. As a resident of Loxwood, I am somewhat familiar with the issues appertaining to the village and wonder how such a number of houses can even be considered for a single village (especially as the number of new dwellings planned for the surrounding villages run in single or low double figures).

I know there are currently issues with drainage during times of high rainfall and of sewerage (I believe Southern Water has already stated that they are at capacity for both drainage and sewerage in Loxwood and to this end, the new houses built by Antler already have a couple of large tanks for waste water, not an ideal situation). I understand that Southern Water have no plans in their next two 5 year planning cycles to increase the amount of drainage or sewerage in the village. As there is already overflow into gardens in Spy Lane and adjacent areas during higher rainfall, I can see this problem being compounded by so many new dwellings. I would be interested to learn how you intend to manage this issue.

There is very limited access via roads currently. The additional traffic generated by so many dwellings is likely to cause considerable strain on the existing road system (which already sees use by many lorries and commuting traffic). What plans are being considered to manage or reduce this level of traffic considering the impact of so many additional dwellings?

The new builds on the land by the surgery in Farm Close: Are there plans for additional access to the housing development, rather than using the existing access to Farm Close, which is already congested during working hours as overflow parking for users of the surgery?

Unless these issues can be satisfactorily addressed, especially with consideration to sharing the load with other villages and effectively managing the wastewater problem, I must register an objection to the proposed plans.

Whilst I am generally in support of much of the principles contained in the document, I wish to object on the following grounds to the addition of 125 houses that it lists on top of what is already allocated for Loxwood.

1) Loxwood has very limited employment opportunities and the plan overstates the potential for additional employment in the village and surrounding area. The vast majority of the people in the village travel outside the area for employment. This will not change under this plan and people moving to these new houses will need to commute for work.

2) Public transport is very limited and is not viable for commuting to work, therefore all those who work outside the village are dependent on cars. Even with the additional developments such as Dunsfold, this is not going to change, therefore the traffic levels in the village will significantly increase, leading to more pollution and a deterioration in the lives of the villagers.

3) Southern Water have already stated the foul waste capacity of the network in the village is at capacity and they do not have plans to upgrade the network with their current plans that cover the period of the document. This was before the recent development on the old conifer nursery site. Therefore any new development must not be allowed until the network is upgraded. This must be a pre-requisite. We have already had a pollution incident with the new houses even though they are not all currently built and occupied. This led to the village smelling of TCP for days due to the disinfecting required of roads etc.

4) Surface water runoff in the village is already a problem and we have experienced numerous flooding incidents, the addition of all these new houses is only going to make things worse. It must be a pre-requisite to sort these issues before any new housing is permitted.

5) You talk about dispersing the houses across the villages, it seems to me the other villages have got off lightly or even with zero new houses and you have decided to push them all into two specific villages, Loxwood and Birdham. Therefore you have not fulfilled this statement. It is grossly unfair to expect Loxwood to bear the brunt when it has already taken more than its fair share of new houses. It seems Loxwood is to be sacrificed to save other villages.

6) The capacity of the Doctors surgery and the Village School are not going to meet the needs of the additional houses. In particular the current school site has no room for further expansion.

I urge you to re-consider and reduce the number of new houses allocated to Loxwood to a sustainable level that can be supported.

We have lived in Loxwood for nearly 15 years, in a house and road of 24 properties that was built 17 years ago, therefore we are not adverse to new homes. We moved here from a large, growing Surrey town to live in a small, quiet village. We understand the need for more housing and have indeed witnessed much local development whilst living here, including Hall Hurst Close (30 dwellings) , Loxwood Green on the nursery site (43 houses) and the current plan of the development of 19 houses in the field beside the Medical Practice.

I strongly object to a further 125 houses being suggested for our village when nearly all other villages (apart from Birdham with 125 and Wisborough Green with just 25) have been assigned NONE. How can this be correct? It is completely disproportionate and unfair!

We recently became very concerned about an incident relating to a sewage spill from the new Loxwood Green development. We now understand there is a 'temporary' measure with a buried cesspit under the communal green as the existing sewers and drains would have been unable to cope. The whole village smelled strongly of TCP over a few days recently, (so of course we were all breathing in the chemicals), apparently after some raw sewage spilled out of this tank! This is a very unsatisfactory situation and before any further development is planned, a permanent solution should be found for the 'temporary' one and any builders wanting to develop land in Loxwood should be liaising with Southern Water and ensure the sewers and drains are capable of dealing with the higher demands new homes bring, at their expense.

I don't understand why the plan talks about employment opportunities in the village, these are extremely limited. We have a shop, butchers, hairdressers and a pub. What are they thinking of? The Joust held on two weekends a year where perhaps there are a few opportunities for car parking marshals?

Public transport is minimal and really needs to be improved if even more houses are to be considered. We have recently submitted our views via the bus survey, let's hope this brings some much needed changes.

Please see below my objections to the allocation of new sites and houses in Loxwood:
- Loxwood is situated on the Surrey/West Sussex border, already there has been 50+ houses built within the past 24 months. In addition to this within the 3-mile surrey border there are approved plans for sites in development for 2000 homes.
- Loxwood has a much higher allocation than other service villages in the new plan and this has been done without any of those other villages needing a new call for sites.
- The Employment opportunities for Loxwood residents resides at around 40 jobs given the facilities the village has. This is matched by Kirdford who have no additional housing allocated as part of this proposed plan.
- Loxwood has a history of flooding given its streams and Canal. Additional houses will remove the grass area drainage and be replaced with hard surface run off areas. This increases the risk of flooding to the already existing community.
- A number of the already proposed sites have a large number of wildlife that reside in the area for example deer, bats and Owls have been seen in the proposed site behind Pond Copse Lane.

As a resident of Loxwood, I wish to record my objection the the new draft CDC Local Plan.

I believe that the continued growth of the village is contrary to the best interests of the local community.
The local infrastructure cannot support the proposed 125 new houses:
Public transportation links are poor - this will inevitably mean a vast increase in private cars using inadequate roads.
Waste water / sewage capacity in the village and surrounding area already exceeds capacity (recent new developments have required the construction of sewage holding tanks)
There is little or no local employment - again meaning more cards on the roads

I am also surprised that planners propose 125 more houses for a small village - this demand is not from local needs, but from sites proposed by developers. Loxwood has seen a significant number of new houses over the last decade - more are not needed or wanted by local people. It also strikes me as somewhat unfair that other local villages have been allocated either none or very few new homes. I understood that when our local Village Plan was adopted several years ago, new development would be controlled through the agreed plan, and no development outside these parameters would be permissible.

In summary I believe that the proposed Local Plan cannot be considered Sound in terms of sustainability and that CDC has not followed national planning guidance in the development of this plan.

I have lived in Loxwood for over 40 years and have watched our village grow in the number of houses and residents.
Following our last neighborhood plan we had a development boundary and were asked to have some 60 extra houses built in the village, about a 20% increase in size.
This did not include the improvement of any local facilities such as schooling, public transport, road calming, sewage etc. etc.

I now hear another 125 houses are proposed to be built in Loxwood in the near future as we are a 'Service Village'. But we have no more services than we had 40 years ago!

I also here that other service villages are not being asked to take any new homes and those that are have nowhere near 125.

My conclusion is that this development plan for Loxwood is totally unsustainable and unnecessary. Local services will be unable to cope. If only new development was spread evenly across all the villages then local services would be able to cope with only small a investment.

I am writing to object to the current proposal to allocate a further 125 dwellings in Loxwood between 2019 and 2035. I have lived in the village with my family for over thirty years and hope to spend many more here.

In my opinion the content and intent of the draft local plan is not sound, because it does not deliver sustainable development. This is because, inter alia:

1. There is no proven need nor demand for more open market housing in Loxwood. Any new dwellings would most likely be purchased by families moving into the area. There is no employment available in the village, so there is no need for more people.

2. Waste water infrastructure cannot cope with existing planned development not to mention further allocations. The waste water system will not be extended by Southern Water. The local road system is at capacity and there is no public transport.

3. Just because developers and land owners want to build houses and make money, therefore identifying potential sites, does not mean that the village wants or needs more housing. the net must be cast more widely and fairly.

Because of these matters I do not believe that the proposal meets the test of sustainability. Further, in my opinion, CDC has not followed national planning guidance in developing it's draft local plan.

I understand that Loxwood parish council will object strongly to the draft local plan, and I fully support them in this.

The village of Loxwood has previously embraced the due planning process by establishing an approved Neighbourhood Plan in conjunction with Chichester DC. The projected housing allocation in that Plan has now been overridden by the current Chichester DC draft Local Plan, which requires a significant increase in that allocation.

I wish to object to the draft Chichester DC Local Plan on the basis of soundness and process in accordance with the National Planning Policy Framework.

In terms of soundness, Loxwood is not a sustainable location for the proposed housing allocation. It fails on numerous environmental, employment and infrastructure issues.

In terms of process, Chichester DC have produced a biased, developer led, allocation of proposed housing sites and have failed to undertake a credible consultative study to establish the most suitable new housing sites, based on National Planning Policy Framework guidelines.

I would like to offer my comments on the Draft Local plans for Loxwood.

I am somewhat concerned that so many dwellings are planned for a single village, where so many villages exist in the area, yet have negligible building works planned. There has been comment made by Southern Water concerning the situation regarding waste water, where Loxwood is at capacity currently and that Southern Water have no plans in either of their five year plans to increase the amount of infrastructure for the management of waste water, how do you plan to manage this issue. I am aware that neighbouring streets in Loxwood (Spy Lane and Burley Close) are already having issues when heavy rain has occurred.

Additionally, the roads that connect the villages around Loxwood were never meant to take the levels of traffic they currently do and the addition of potentially around 250 more vehicles would place a massive burden on the roads and create jams at peak times. Additionally, access between the new estates and the main roads appear to just use existing access points, such as the plan for the land adjacent to the Medical Centre in Farm Close.

It would seem that your plans for Loxwood are to create effectively a dormitory town, as there are few work opportunities actually in the village and immediate surrounding, thus people must commute considerable distances for work. This obviously has an impact on the environment and for pedestrians. How do you intend to ensure that the environment will be protected and that the increase in road usage will not put pedestrians at risk?

Loxwood is an historic village. It currently retains considerable character as such. how do you anticipate to maintain the essence of the village with so much expansion in such a relatively small area?

Finally, I am curious about the procedures (CDC) followed regarding national planning guidance, the 'desk top studies' and consultations based on those studies. Especially considering the lack of sharing the burden of development across the local parishes.

I would like to comment on the CDC Local Plan Review 2035 that is in its consultation period at the moment.

The first consultation phase of the Local Plan proposes to allocate a further 125 houses in Loxwood for the period 2019 to 2035. This is in addition to the 60 already allocated in the current Local Plan.

I would like to object very strongly to this allocation. I understand the National Planning Policy Framework requires that local plans and planning applications deliver sustainable development. A plan which does not deliver sustainable development is not considered to be sound.

I would like to object on the grounds that this proposed development is not sustainable due to infrastructure capacity constraints, in particular relating to waste water treatment, roads and transport.

1. Loxwood sewerage infrastructure has no more capacity for any more development and Southern Water have stated they do not have any plans to update the infrastructure in its 2020 to 2025 spending plans.
2. Loxwood does not have any viable transport system, only one bus a day going to Guildford.
3. Loxwood does not have any employment opportunities therefore residents have to commute to work by road.

125 new houses in Loxwood does not meet the tests of sustainability defined in the Draft Local Plan and thus the plan cannot be considered to be sound as defined in the NPPF.

Please find below my reasons for objecting to the new draft CDC Local Plan which is in its first consultation phase:

The NPPF requires that Local Plans and Planning Application deliver sustainable developments. I do not believe that the suggested development of a further 125 houses in Loxwood for the period 2019 to 2035 is sustainable in a village that will, if this proposal goes ahead mean more than 200 houses will be added to a small village in less than 20 years.

I do not believe the suggested developments are sustainable, mainly because the Loxwood sewerage system is at capacity and Southern Water have no plans in the foreseeable future to upgrade this system. On our latest development in the village, the Developer has had to install sewerage holding tanks that will have to be emptied by a tanker. Is this progress??

Loxwood also has very little demand for open market housing, most houses are bought by people moving from elsewhere for a variety of reasons.

These two issues do not meet the tests of sustainability defined in the draft Local Plan.

I note that Loxwood has been allocated 125 new houses. Kirdford, Plaistow and Ifold have not been allocated any new houses and Wisborough Green just 25 houses. As far as I am aware, no Parish Consultation has taken place about site allocation and no effort has been made to share the housing burden across the three Parishes. I believe this means that CDC has not followed National Planning guidance in developing its draft Local Plan.

There are sites in all villages which are available for sustainable development and which can contribute to the overall housing needs.

Many of the villages have suitable services to allow for sustainable development.

Allocation of a fixed number of houses (as a % of existing dwellings) will encourage improved neighbourhood planning ('neighbourhood plan -lite') in villages who will have sufficient time to prioritise low density developments in their village (and which will not have a detrimental impact on their village)

The plan for 125 new houses in Loxwood does NOT meet the tests of sustainability as defined in the draft local plan and thus the plan cannot be considered to be sound as defined in the NPPF

I wish to register my objection to the CDC Local Plan for Loxwood for the following reasons.
We are already in the process of building 60 new houses which I did not object to. This plan proposes a further 125 houses in Loxwood but very few in surrounding service villages; the numbers should be distributed more fairly.
The village has existing sewage problems which have been exacerbated by the latest housing development. I understand that Southern Water has stated that they have no plans to update the infrastructure in the near future. Also the village already suffers areas of flooding, more housing will compound this.
There is very little local employment.
Our public transport system provides one bus a day and so residents have to use their own transport to get to a more varied transport system.
The school is nearly full and the site is cramped.
For the above reasons I do not feel that such a large increase in housing in Loxwood would be an asset to the village or attractive to potential purchasers.

At a meeting of the Loxwood Parich Council (LPC) last week we were informed of the content of the draft Chichester District Council (CDC) Local Plan. This includes a consultation phase with regards to the allocation of a further 125 houses in the parish.

I am horrified that my local District Council, to which I pay just under £3,000 per annum, could seriously wish to proceed with this building allocation proposal. My comments are as follows:

- Housing Allocation: It would seem that the allocation of further housing in this part of the county has not been based on careful planning (traffic, sewage, schooling, public transport etc.) but solely on the response received from developers in the area. So you find yourselves in the embarrassing situation where Loxwood has been allocated 125 houses while Wisborough Green has 25 and Ifold/Plaistow have none. There is no record that the parishes were consulted and neither has there been any effort made to share the housing burden between the parishes. What a great way to plan......the numbers add up so let's go ahead before anyone notices.....no time consuming planning! In today's world this is just not acceptable.

- Loxwood Sewage: It is a well known fact that the Loxwood sewage system is already at capacity even without all 60 current houses being build coming on-line. Southern Water have confirmed that they have no plans to update infrastructure in their 2020/2025 plans. Already the sewage from the new houses on the Loxwood Green development is currently going into huge holding tanks (septic tanks?). These will need to be emptied by tankers full of raw sewage from 60 homes?

It is quite clear that this plan for 125 new houses in Loxwood does not meet the tests of sustainability defined in the draft Local Plan. Neither has the CDC followed the national planning guidance in the preparation of the draft Local Plan.

I wish to register my strong objection to the local plan for Loxwood to build yet more houses. My main objections are as follows:

1. We have already had a new estate of houses just completed and yet a further 125 are proposed. The building of new homes is important and yet why is the responsibility not shared amongst neighbouring villages. Plaistow,,Ifold and Kirdford have not been allocated any. This is unreasonable and illogical and sacrifices Loxwood's village identity to spare those listed above.

2. Pressure on services. Both the doctor's surgery and the local school will not cope with demands resulting from the endless building applications.

3. It is accepted and formally acknowledges by Southern water that the Loxwood sewage capabilities have NO MORE CAPACITY

4. There are areas of Loxwood already prone to severe surface water flooding.

5. I live on Loxwood road and the traffic is already becoming a problem at rush hours. The council stubbornly doesn't change the limit from 40 mph to 30 mph and the limits are often massively exceeded. The last thing we need to do is add to the traffic.

This whole plan of expecting Loxwood to bear 100% of the brunt of the future building plans is as illogical as it is highly suspicious and I think questions should be asked as to why the other villages are so conspicuous by their absence in these plans.

Having looked at CDC's proposed local plan for 2019 to 2035, I am concerned that the planned 125 extra houses for Loxwood village, plus the 60 houses already in build as part of current development plans will cause a breakdown in the community as our services will be unable to cope with the new homes and residents.

The main road through the village is getting busier and busier, new houses in the village along with the developents just north in Alfold, Surrey will create a traffic problem.

Our school is only just below maximum intake. So we can't have any more young families in the village.

I believe Southern Water do not have a budget for much needed improvements in the local sewage system. The development at Loxwood Green has already spilt sewage onto the road.

Public transport is almost non existent in and out of Loxwood.

I am totally against this requirement for a large increase in the size of the village. Surely housing should be spread as evenly as possible throughout many villages in the area to dilute the impact on local services.

We are writing to you to voice our very strong objections to the proposed plan for 125 new houses for Loxwood.

This must be one of the unfairest proposals ever surely. Along with Birdham, it seems to be proposed that Loxwood should bear the brunt of the housing requirements of the government for this area. Other villages nearby have escaped with no development being proposed at all, so why has Loxwood been picked on? It surely must be driven by greed of landowners and developers and not by common sense.

We believe that the plan is not sustainable in any case for a variety of reasons.

* There is little opportunity for employment in this area meaning that any new residents would be taking to what is already an overused and overcrowded road meaning more pollution and danger to residents in order to get to their place of employment. There is one bus a day to Guildford so that means of transport is not an option.
* Loxwood is in a flood risk area so the arrival of thousands of tons of concrete is not going to contribute to the facilitation of water draining away.
* We are aware that Southern Water have no immediate plans to update their infrastructure. Already the new housing estate being constructed is having to rely on holding tanks for its sewage which will mean heavy tankers having to come to the village on a regular basis. This will doubtless have to be repeated for any future developments, adding to the heavy traffic already passing through the village.
* Probably any new housing would be purchased by people moving to the area rather than local people, so why is there the need for additional housing?
We believe the burden of providing extra housing should be divided out more fairly across the area and not placed solely on one village with inadequate drainage, virtually no public transport and an already busy road and no obvious need for such a large increase in its population. We further believe that Chichester Council has not followed national planning guidelines in developing its draft Local Plan and should have a serious re-think.

We hope you will give our letter due consideration and come to a different conclusion about Loxwood's housing requirements.

Although I am a parish councillor, I am writing as a private resident of Loxwood within Chichester District.
Whereas I fully understand the need for additional housing within the district as imposed by Government under their new Objectively Assessed Need (OAN) formula, I must strongly object to the allocation of 125 additional houses within Loxwood parish as detailed in policy S5 of the CDC Local Plan Review 2035 - Preferred Approach document for the following reasons:-

1. The process of allocation within the designated Service Villages is flawed due to the lack of consultation in advance of this determination with any of the local parishes, contrary to best practice and the NPPF. It is also contrary to CDC's own policies on Community Involvement and the CDC Local Plan Review 2035 - Preferred Approach document which states that "an essential part of the process has been community engagement". NO such engagement has taken place with Loxwood nor do I suspect with any of the other parishes prior to the determination of allocated housing numbers. The NPPF states that Planning Authorities should "Work with the support of their communities and with other authorities if appropriate" and "should identify suitable locations for such development where this can meet identified needs in a sustainable way". The omission of any such engagement and involvement is therefore contrary to national and local policy.

2. The allocation of 125 houses to Loxwood in the North of Plan Area is disproportionate and unfair. Within the current "Made" CDC Local plan effective for 2015-2029 the three designated Service Villages in the North of Plan Area were allocated new housing targets equally at 60 per village, without any reference to the HELAA current at that time. Loxwood decided which sites were viable and achievable to accommodate this number through the formulation and making of a Neighbourhood Plan.

Under the CDC draft Local Plan Review 2035 - Preferred Approach document, CDC has accepted all the sites submitted under their recent call for sites exercise within Loxwood. These were submitted not by the Parish Council, but by local land owners and developers who have significant financial self interest in putting forward sites which have not been reviewed or assessed by the Parish Council in any way. Other Service Villages in the North of Plan Area have been allocated either zero additional housing in the case of Kirdford or only 25 in the case of Wisborough green on the same premise, as CDC claim that Kirdford submitted no sites under the call for sites exercise and Wisborough Green only one site. This is clearly a case of developer led planning which is contrary to National and locally stated policy.

All the service villages within the North of Plan Area should have been challenged to provide a proportionate number of houses under this proposal irrespective of the HELAA or call for sites exercise, as was the practice before. This would have resulted in 50 additional houses per village and would be a fairer and more policy compliant methodology. I am also somewhat distressed to see that the Land South of Loxwood Farm Place has been re-submitted by the developer despite being the subject of 3 judicial reviews and a resounding success for CDC in winning their case in the High Court supported by a number of hard working local residents from Loxwood who put in a considerable amount of time and effort into ensuring that their Neighbourhood Plan was robust enough to resist inappropriate development within the parish. CDC will effectively have wasted their own and these residents' time, effort and money if they continue to allow this site to be put forward for development let alone CDC costs involved in defending the High Court challenge.

3. The whole premise for additional housing development within the NPPF and also the CDC Local Plan Review 2035 - Preferred Approach document is that of sustainability. In Paragraph 4 of the Local plan review document CDC defines sustainable development as:-
 The pattern of need and demand for housing and employment across the area;
 Infrastructure capacity and constraints, in particular relating to wastewater treatment, roads and transport;
 Environmental constraints - avoiding flood risk areas, protecting environmental designations, landscape quality, the historic environment and settlement character;
 The availability of potential housing sites, their deliverability and phasing

Loxwood has few if any employment opportunities, so the demand for housing in the parish is not driven by local employment needs. Indeed most of the residents of Loxwood who work need to travel outside of the parish and use private transport to do so. Loxwood is a popular location not because of need, but because people want to move into what is a delightful rural country location with the benefits that this can bestow. Indeed according to CDC's Landscape Capacity Study document referred to in the draft Local Plan Review - 2035 document, Loxwood has low, or low to medium capacity for development. Despite this CDC has described Loxwood as a "larger Village with the potential for development". These are contradictory statements and demonstrate the lack of detailed attention given to the allocation of housing, relying more instead on what developers put forward than their own analysis of need or capacity.

The public transport situation within Loxwood parish is laughable. There are no sustainable services which would allow workers to travel at peak times to their places of work. There are no bus services that are available more than once per day or only on two days per week. This is hardly sustainable transport.

It is well known by CDC that Loxwood has a fragile and failing waste water sewage system. It is regularly at maximum capacity due to the inundation of surface and ground based water. Southern Water themselves say that there is insufficient capacity for further connections to the system without significant infrastructure renewal or improvement The Nursery Site development in Loxwood has been the subject of an enforcement order due to the Antler Homes connecting illegally to the system and they have had to provide attenuation tanks to allow a trickle discharge into the system as a temporary measure until Southern Water can improve the overall infrastructure. Temporary in this case means a relatively permanent solution as Southern Water have no plans for upgrading the sewage infrastructure in Loxwood in their current or next five year capital spending plans. There is no promise that the following period will include an upgrade to the Loxwood system either. Therefore, in terms of sustainability, how can CDC require Loxwood to accommodate a further 125 houses plus windfall developments of less than 6 houses to go ahead given the state of the sewage system? This is clearly unsustainable.

In addition to sewage, Loxwood Village had the highest number of flooded houses (16) of any village in Chichester District in the 2013/14 storms. This was in the main due to the bursting of the banks of the Loxwood Stream. Further urbanisation of the village will place greater pressure on the surface water disposal most of which relies on ditches feeding into the Loxwood stream.

Finally on sustainability, under the proposed plan with windfall developments, Loxwood will see around 200 new dwellings in the plan period out of a total current stock of around 650 dwellings. This is a 30% increase in this essentially rural village (CDC's description). This level of urbanisation will without doubt change the historic nature and settlement character of the village putting excessive pressure on the local School, which is already near to capacity, and the other services such as the medical practice. This is contrary to the Sustainability statements in both the NPPF and the proposed local plan.

In conclusion I would urge CDC to take into account all of the above arguments and to review its housing allocations for the Villages in the North of Plan Area so that they are more equitable and realistic given the nature of this village and its inability to provide any significant number of sustainable dwellings now or in the near to medium future. Other villages should be challenged to come up with additional housing sites to take up any short fall in required housing allocations in a fair and plan led approach to housing numbers.

I am writing to strongly object to the allocation of an additional 125 houses to Loxwood as part of your review of the CDC Local Plan, Policy S5, currently issued for consultation.
Loxwood was tasked to accommodate 60 houses under the current CDC Local Plan. Whilst recognising that Government is demanding a higher level of house construction across the country, I believe that the additional number of 125 houses allocated to Loxwood is disproportionate and unfair given the previous methodology of allocation. Neighbouring villages in the North of Plan area have either been allocated zero additional houses or, for Wisborough Green, only 25. We were not consulted on this allocation or the process for determining these numbers. The 3 so called Service Villages in the North of Plan area are of similar size and have similar facilities. Why then has Loxwood been singled out to accommodate 5 times as many houses than Wisborough Green?
It seems to me that this is purely based on the sites put forward by developers and not for any other proper planning reason.
Under national legislation, the NPPF states that any development should be sustainable and your own Local Plan document details how this is interpreted. Loxwood is classified as a rural community and does not have a demand for housing as a result of employment need as there is little employment in the area and little chance of that situation changing. Also there are no sustainable transport links which would assist residents in getting to their places of work which by necessity are outside the parish and even further afield. The nearest main employment concentrations are Guildford and Horsham with many local resident commuting to London from these two locations. There is no useable bus service and everyone needs to use private cars.
Another aspect of sustainability stated in the Local Plan document is the need for a sustainable sewage infrastructure. Loxwood has a fragile and an already at capacity sewage system - a fact recognised by Southern Water. The recent Nursery Site development by Antler Homes in the village was required to provide a significant improvement to the existing system before connection would be allowed. They failed to do this and are the subject of an enforcement order from CDC planning. Their solution of two attenuation tanks is meant to be temporary. However Southern Water cannot guarantee any infrastructure upgrade for the foreseeable future. This situation is unsustainable now, let alone for the proposed 125 additional houses.
To propose these additional housing numbers is not only inequitable and unfair, but also unsustainable by your own definitions. I would therefore urge CDC to reconsider their housing allocations in a more compliant and appropriate manner seeking more housing from neighbouring villages and reducing significantly the number's required in Loxwood. In addition they should address the issue of a sustainable infrastructure with Southern Water and not require any further development in the Loxwood area until such time as an upgraded waste water disposal system is in place.

The new draft Chichester District Local Plan proposes to allocate a further 125 houses in Loxwood, but this does not meet the tests of sustainability for the following reasons:-
1 The sewage infrastructure has no more capacity
2 The only public transport is one bus a day
3 Residents have to commute to work
4 Loxwood has no demand for open market housing
The CDC has not followed national planning guidance as no parish consultations took place about site allocations and no effort was made to share the new houses across the three parishes defined by CDC as "service villages", being Kirdford, Plaistow/Ifold and Wisborough Green.

As a resident of Loxwood Village I would like to make several objections to your proposal to build a further 125 homes in our area in the period 2019 to 2035, without fully appreciating the likely implications to our immediate area.

SUSTAINABILITY
Our general area, which is right up on the Surrey border, with Alfold being at the top of the hill less than half a mile away, is already experiencing the building of many new homes, and the traffic on the road we live on, the B2133, has dramatically increased as a result. In addition, as you will be aware, there have been many homes built in nearby Billingshurst, as well as in other nearby areas such as Cranleigh in Surrey where over 1000 new homes have been built: this is our nearest town and only ten minutes away. I am sure you will appreciate this means much more traffic. Also plans have recently been approved in Waverley District for more than 2000 new homes to be built on Dunsfold Airfield, which again is very near to us. All this expansion will increase traffic on our roads dramatically. The main road through Loxwood the B2133 has not been improved for many years. Both in the centre of Loxwood and in Alfold village when cars are parked, which is frequently, one way traffic exists. We also have increasingly seen large lorries using this run to avoid the A29. So, if another 125 more houses or thereabouts are built in Loxwood in this coming period, a lot of funding will be needed to be spent on our and surrounding areas' infrastructure.

SEWAGE SYSTEM
As you will be aware our sewage system in Loxwood is already inadequate for our needs and sewage holding tanks are already having to be used at our latest new village building site. Certain parts of the village also suffer with flooding from streams and surface water when the rains come, and this is before adding further waste water coming down from new building in nearby Surrey. I also understand that Southern Water have no plans for the next few years to improve their facilities in this area.

PUBLIC TRANSPORT
Currently we only have one bus a day that goes to Guildford, allowing one two hours there before having to return: not a lot of use. If you know the A281 from Guildford to Horsham you will realise that the road is so narrow in Bramley that there are regular traffic jams at rush hour. I appreciate that you are thinking of the needs of West Sussex however for us who live in this part of the county, nearby Surrey is critical for us.

EMPLOYMENT
There is very little employment nearby and good road communications are vital. Thus good new road improvements will be vital if your plans are to be implemented. The present rate of movements in the rush hours do not make for a contented work force.

UNEQUAL HOUSE PLANNING
It is obvious that 125 houses being allocated to Loxwood is totally unreasonable and the proposal has been driven by developers making your decision easier for choosing sites. How can you reasonably justify allocating only 25 new houses to Wisborough Green and none to Kirdford, when you know full well that 60 houses were allocated to all three sites in the previous plan. Why has no attempt been made to share the housing burden equitably across the three mentioned villages? I understand that no consultation of potential housing sites has been undertaken with Loxwood parish, if so where is the local democracy here that we hear so much about?

SCHOOL
With your proposed new building of 125 new homes think what allocation you will have to make for our school?. As you no doubt will know the school was built in the 1970s to last 25 years, and last year it celebrated its 50th anniversary and many basic items now urgently need replacing, and consider what allowance you will have to make for this? If your plans go ahead you will have to consider how many more children will need to enter the school?

You can see from this letter, and others that you will have received, that most of us are really upset that people who do not live in this area are trying to unilaterally ride roughshod over us. Please also do not forget
that unlike those of you who come from Chichester and many other areas, you do not also have to suffer from regular airplane noise from Gatwick Airport, which also we have little control over. Please consider all these aspects before enforcing your preliminary proposals in a non-democratic way, how is this fair and reasonable, we live here and will have to pay the price, not you!

4.33 indicates new settlements must 'support the provision of key infrastructure and community facilities' - our infrastructure and facilities are overloaded with roads, school and facilities already full and overflowing.
Be 'comprehensively planned in consultation with existing communities and key stakeholders' - we have offered sites 200 homes which are sustainable and achievable but you have slammed at last minute a 'wildlife corridor' across those areas.
'does not undermine their separate identity' - Fishbourne already has building to our North, South and East boundaries so building on Bethwines would further errode our separate identity.

A minimum of two hundred more houses between Birdham and West Wittering on top of the hundreds already built in this area makes no logical sense.

As a local resident of Loxwood I am alarmed and surprised that a small village with little public transport and a limited amount of employment has been selected to receive a further 125 properties in addition to the 60 new properties that are currently under construction. I do not feel that this village can sustain this number of new houses, given the lack of capacity of the foul and surface water having personally encountered foul water lifting the manholes on my property when we have a downpour of rain. It will affect the landscape value of this small rural hamlet and property should not be just sited where there is a green field.

Whilst I appreciate there is a national property need, I do think this new plan is sound and the numbers seem to be completely imbalanced with other similar villages.

As a local resident of Loxwood I am concerned about the proposed allocation of additional housing within the village. The proposed plan seems to be not sound, not giving regard to its sustainability with the lack of public transportation, limited capacity of schooling, lack of demand for housing local employees and lack of capacity of our sewage system.

We already have new housing being built in the village and it appears that the allocation is completely unbalanced when compared with other similar sized villages in the district.

Whilst I appreciate there is a national housing need, the allocation needs to be reviewed.

Policy S5 proposes to allocated a further 125 houses to the parish of Loxwood in addition to the 60 already allocated in the Loxwood Neighbourhood Plan (LNP). Including windfalls this will add a further 200 houses over the period 2018 to 2035. All of the new houses will be built in the village of Loxwood which equates to approx. 40% increase in the number of houses over a period of 17 years. This is not considered sustainable in accordance with the NPPF and CDC's own draft Local Plan (LP)
Page 35 of the LP defines sustainable development as:
1)The pattern of need and demand for housing and employment across the area;
2) Infrastructure capacity and constraints, in particular relating to wastewater treatment,
Roads and transport;
3) Environmental constraints - avoiding flood risk areas, protecting the environment
4) Designations, landscape quality, the historic environment and settlement character;
5) The availability of potential housing sites, their deliverability and phasing
Loxwood does not have any medium or large scale employment opportunities thus residents have to commute by road to work. Equally, there is no viable bus service so shopping, entertainment, commuting, visits to hospital also have to be carried out by car.
The Loxwood sewer system is at capacity as defined by Southern Water responses to planning applications 17/02370/FUL (Farm Close) and discharge of condition 10 for the Nursery site 18/02247/DOC.
The Farm Close site has so far not proved viable for the developer because of the requirements of Southern water and the Nursery site was not allowed to connect directly to the main sewer because of capacity issues. Southern Water have stated that the Loxwood sewer system cannot meet the demand of a further 125 houses and have admitted that they have no intension up upgrading the system in the foreseeable future. Their priorities lie elsewhere.
Thus the allocation of a further 125 houses in Loxwood is not sustainable in accordance with the requirements of the NPPF and CDC's own draft LP.
The two other "Service Villages" in the North East Part (NEP) of the district, Kirdford and Wisborough Green have been allocated zero and 25 houses respectively in the draft LP. In the existing LP, Loxwood, Kirdford and Wisborough Green were all allocated 60 houses each. The allocation of housing in the draft LP was developer lead and the methodology carried out by CDC to determine the housing allocations was not consistent with Planning Practice Guidance which supports a more consultative approach to housing allocation in LP development. No such consultation took place. CDC adopted a dictatorial approach and would not listen to reason. Thus CDC have not followed the intent of Planning Practice Guidance for the development of a Housing and economic land availability assessment.

Resident of West Wittering.
Birdham is already providing significantly more home than the adopted Local Plan requires. The village has one shop and a petrol station and NO other retail facilities. The further 125 in this Plan is totally inappropriate.