Policy S5: Parish Housing Requirements 2016-2035

I would like you to consider this letter as a formal objection to the CDC Local (development) Plan in its current form. Specifically to the proposed allocation of 125 new houses to Loxwood village in addition to the 60 contained in the existing Local Plan.

I accept that there is a nationwide need for new homes, but I object to the scale of this plan as it impacts Loxwood based on the principles:-

* The process thus far appears to have allowed developer led site availability to direct a disproportionate share of new build to Loxwood village.

* Development on this scale is not compatible with existing and planned infra-structure and services in the Loxwood area.

Developer Led Process
The current proposal allocates 125 new homes to Loxwood, yet only 25 to Wisborough Green and none at all to Plaistow, Ifold and Kirdford. All these villages are similar in their provision of services (eg school, shops) that are required to support new housing development. Why therefore has Loxwood been allocated the huge majority of the proposed development? If, as it appears most strongly, it is the result of sites being declared available by land owners and developers, then it is reasonable to challenge why this criterion is given undue weighting in the overall process. Further consultation through the Loxwood Parish Council should be carried out as a matter of urgency.

Infra-Structure and Services
Loxwood village has expanded through new housing developments consistently over recent years. The situation has now been reached whereby certain services essential to support an increase in the village population are at or near capacity:-

* Sewage and surface water drainage is a matter of significant concern within the village (which is prone to flood in periods of high rain and/or water run off). The recent 40+ housing development on the old Nursery land required the installation of sewage holding tanks with the associated need for emptying by means of road tanker. Southern Water has gone on record stating that its systems in Loxwood are at capacity. Furthermore it has no plan in the foreseeable future to address the situation.

* Loxwood primary school is almost full. Indeed it has converted space occupied by its library to provide much needed classroom capacity.

* Public transport in Loxwood is almost non-existent. The once a day bus service between Cranleigh and Guildford does not provide an alternative to car usage for the vast majority of journeys.

* Most Loxwood residents in employment need to commute to nearby towns, notably Guildford and beyond or Horsham/Crawley district due to the lack of job opportunities in what is essentially a rural residential and agricultural area. The occupants of new housing development will probably need to find similar employment. The pressure will increase still further on local roads, notably the A281 Guilford-Horsham road. [This is under significant pressure driven by approved developments at Alfold and Dunsfold Park in the adjacent Waverley DC area of Surrey]

In conclusion I therefore object to this existing CDC Development Plan as I do not believe it sustainable within the context of the Loxwood area infra-structure and I do not believe that the process thus far has been fair and equitable within the North-East area of Chichester DC.

I would like to register my objection to an element of the current proposals for the revised CDC Local Plan.

My objection is specifically regarding the allocation of 125 more houses to Loxwood .

In principle, I do not have an objection to more housing. However, there is a major problem that nobody seems to be addressing about the current state of the Loxwood Sewage infrastructure.

It is well known now that the previous development (Loxwood Nursery site) had to fudge the sewage infrastructure with holding tanks which require periodic emptying.

I further understand that CDC and Southern Water are not working together to resolve this issue and as a result, Southern Water have excluded improvement to the Loxwood infrastructure in their 2020-2025 spending plans.

To add 125 more houses without the sewage infrastructure being adequately improved first can only be viewed as negligent to the community.

I write in connection with the proposal contained in the Draft CDC Local Plan to allocate a further 125 new houses to Loxwood in the period to 2035. This is in addition to the 60 already contained in the current Local Plan.

Loxwood has already seen significant development in recent years. The local infrastructure is insufficient to support the proposed development. Loxwood has no meaningful public transport and very limited local employment opportunities. Furthermore, the majority of houses built in the village recently are not being used to satisfy local demand but are being purchased by people moving into the area. The consequences of the above are obvious, with car journeys being the only way for people to travel. The road network is incapable of supporting the proposed level of development.

Furthermore, the sewage system servicing the village is already at capacity and Southern Water has not earmarked spending on the infrastructure in its planned spending through to 2025. Indeed, recent development in the village has required the installation of sewage tanks which require emptying by tanker, which in turn increases road traffic volumes.

Given the above I cannot see how the proposal to build an additional 125 new houses in Loxwood meets the required test on sustainability.

In addition to the above, it is my understanding that national planning guidance requires district councils to consult parish councils over site selection and allocation. No such consultation has taken place with Loxwood Parish Council and therefore CDC does not appear to have followed national guidance in putting together its Draft Local Plan.

I am writing to object to the proposed allocation of 125 houses in Loxwood, West Sussex.

Soundness of the plan
Any plan which is submitted needs to be considered sound (as defined in the NPPF) and I conclude that having an additional 125 houses built does not meet the criteria of sustainability defined in the local plan.

This conclusion is based upon the following, that the local plan should seek to deliver sustainable development:-

- Environmental Constraints - avoiding areas at risk of flooding, environmental designations should be protected, quality of the landscape, the historic environment and settlement characteristics.
- The capacity of the infrastructure and its constraints, i.e. wastewater treatment, roads and transport.
- The local water utility provider "Southern Water" have stated that the
capacity in Loxwood for sewage has been reached, i.e. the current
infrastructure is at maximum capacity already. Further, no provisions /
budget in years Southern Waters 2020 - 2025 plan is made to increase this capacity.
- Parts of Loxwood are already prone to surface and fluvial flooding.
- The pattern and demand for housing and employment in the area.
- Employment in Loxwood should be considered minimal and most people
would have to commute to work.
- There is only one bus a day in Loxwood (which runs outside of the major core hours for working).
- Local demand for housing is minimal, the majority of houses being sold to
people moving in from other areas.
- Building site availability and any necessary phasing.

The Planning Process
CDC has not followed the nation guidance for planning and development in relation to Loxwood.

I have concluded this based upon CDC's approach which was:-
- CDC issued a call for potential development sites, developers aware of this requirement in the Loxwood locale put forward a number of sites upon which some 125 houses have been proposed. Wisborough Green has been allocated 25 houses, whereas Kirdford, Plaistow and Ifold have been allocated no new houses. i.e. this process seems to have been driven by developers seeing an opportunity. Guidelines state that a desktop study should be carried out by District Council and then a subsequent consultation should have taken place.
- In the existing plan Loxwood, Kirdford and Wisborough Green were allocated
60 houses each. There have been no parish consultations on any site allocations and there seems no effort made to ensure that the burden of housing should be shared across these 3 parishes (defined by CDC as "Service Villages").

I object most strongly to the proposed development of 125 new houses in Loxwood.
SUSTAINABILITY
The infrastructure of this village is being tested in the extreme with flooding of the stream
and the sewage overflow of the new houses at Loxwood Green. I understand that the local water company has no current plans to rectify these problems.
The busy B2133 runs through the village. This meets the A281 at Alfold. Both these roads are full of traffic and more houses in Loxwood, probably with 2 cars each, with commuting owners would make the problem even worse, the roads could not cope. There is no work in the village, just 4 shops, so all newcomers would have to commute to Guildford/London, using these roads making the traffic far worse.
The village primary school is full, has no free places and 125 houses would most certainly have children as residents.
The village doctors surgery is very full, and would not be able to cope with such an influx of new residents.
These points do not meet the sustainability requirements for the village and are therefore not Sound.
OTHER VILLAGES
It is wrong that Loxwood been singled out for such a large development whereas Wisborough Green has been required to take a development of only 25 houses and the other neighbouring villages, Plaistow, Ifold and Kirdford have not been required to build any. This seems to me to be totally unfair - surely the Council's requirements for new housing should be spread evenly through the villages that are not within the South Downs National Park.

I am writing to object to the development of a further 125 homes in Loxwood for the following reasons:

1. Traffic and transport - we do not have any appropriate form of public transport to support this new influx of housing with only one bus a day to Guildford, I cannot imagine how many more cars will be on the road through the village. The road is already strained. The A281 is under immense pressure also.

2. Child Safety - I have to cross the main road through the village four times a day on a school run to the Pre-School and Primary School and the road is exceptionally dangerous. The parked cars mean that it is impossible to see what is coming, sometimes until you are almost half way across. There are no considerations for my elderly neighbours making the same crossing to the doctor's surgery. This makes me extremely anxious and this is an accident waiting to happen. More cars on the road mean that my children will never feel safe to make that big decision for themselves of when to cross the road.

3. Pre-School - The Pre-School is already over-subscribed. It can take 17 children in its small building and there is already a waiting list for the next two school years. The alternative provisions are in Ifold, Rudgwick, Dunsfold and Cranleigh, all adding to traffic on the road through the village.

4. Primary School - The Primary School is seriously under-funded and more children just means additional pressure and demand on already scant resources.

5. Antler Homes - Antler Homes have not yet sold all of their 43 homes which were first up for sale almost 2 years ago. There just is not the demand for housing in this village.

6. Sewage - Southern Water has said that Loxwood sewage insfrastructure has no more capacity and there are no plans to update this infrastructure. The use of sewage holding tanks will mean yet more traffic on our unsuitable roads.

Please ensure our voice is heard as villagers. I speak for not only myself, but also for concerned neighbours and in particular parents of small children.

I am very concerned with the number of additional houses in Loxwood Village proposed under the above plan.

Surely the proposals for additional houses should be led by local needs and sustainability rather than by developers.

I would like to record my specific comments:
1- The plan does not meet the sustainability requirements as follows:
- transport, there is only one bus a day to Guildford, and two buses a week to Horsham. Any additional houses will put further pressure on the local roads and lead to increased pollution.
- employment, currently there are only very limited employment opportunities in the surrounding area, thus new residents will need to drive to their place of employment as the current transport does not operate at the times required by those going to work. This is likely to lead to two cars per house, even more cars on the already crowded roads
- the existing foul water infrastructure- with the new Nursery Green development there has had to be installed a foul water holding tank as the current system cannot cope with the current demand. The foul water in the holding tank can only be pumped away when there is capacity at the treatment works. According to Southern Water there are no plans to increase capacity. How will the system cope with the demands on it of additional houses?
2- Unfair distribution of houses within the North area with the surrounding villages mostly not being allocated any additional houses

I hereby wish to formally object to the Local Plan Review as part of the current consultation,
specifically in regard to the proposals for new houses planned for Loxwood.

My objection is based on the following grounds:

(1) Having recently purchased a new home in Loxwood myself, it is clear that this village cannot further sustain additional development to the scale outlined by the CDC Local Plan without significant additional support to the local infrastructure. It appears CDC may have neglected proper analysis and due diligence regarding the sustainability of the sewerage infrastructure, specifically its current and future capacity limitations. I would expect to see evidence of plans from Southern Water explicitly committing to significantly improve the infrastructure in the coming years to meet this plan sufficiently. Lastly, I'm also concerned with the already increasing burden placed on local roads, the lack of a public transport system and also the expected impact to the (only) local school which already suffers funding issues - as a parent and commuter myself, these are also key interests of mine.

(2) I am very concerned that CDC may not have followed due process regarding the allocation of houses to the various proposed sites. I would ask to see evidence of a "desktop" study and also evidence of consultation with local parishes in line with national planning guidance. I am somewhat concerned that Loxwood is being targeted to bear the brunt of the development burden (compared to other villages) and therefore I request transparency and clarity on the allocation process itself as a whole.

In summary, a small village like Loxwood cannot simply absorb a significant number of new houses without severely negatively impacting existing residents - this is not a sound plan and there are concerns that a proper process has not been followed. Therefore, I strongly object to this proposal and request revisions are made to address the concerns of our local parish council.

I am writing to lodge my objections to the above plan as they relate to Loxwood Village.

First as a general comment the proposals are led by developers , who will always take the easy option and the one to make the most profit for them, rather than led by local needs, and the sustainability of the proposals.

My specific objections:
1- Unfair distribution of houses within the North area with the surrounding villages mostly not being allocated any additional houses
2- Sustainability, does not meet the required elements required to meet policy criteria, in particular:
a- the existing foul water infrastructure- the current system is at capacity, note the Nursery Green development has had to have a holding tank installed with the foul water only being pumped away when there is spare capacity at the treatment works. How will the system cope with the demands on it of additional houses. According to Southern Water there are no plans to increase capacity.
b- transport , virtually non existent with only one bus a day to Guildford, and two buses a week to Horsham. Thus any additional houses will put further pressure on the local roads and lead to increased pollution.
c- employment, the only employment opportunities in the surrounding area are very limited meaning that those occupying the new houses will need to drive. With modem family requirements this will mean an additional two cars per house, with no suitable transport further pressure on the already busy roads.
d- education, the local primary school is very close to its practical operating capacity, where will the additional primary school children go?
3- If the additional 125 houses are agreed it will result in 30% growth of houses over the next 18 years, seems a very unfair distribution of new houses compared to other areas in the North Plan.

I am writing concerning the new draft CDC Local Plan which proposes to allocate a further 125 new houses to Loxwood in the period 2019 to 2035 in addition to the 60 houses in the current Local Plan.

I believe that this plan is not sound as such development is not sustainable. Loxwood has undergone significant development in recent years and the local infrastructure will not support further development. There is no public transport system to speak of and limited local opportunities for employment. There is little demand for housing locally with most houses built in the village recently being purchased by people moving into the area. The road network cannot support the proposed level of development as car journeys are generally the only way for people to travel.

In addition, the sewage system servicing the village is already at capacity and with no spending planned this position will only worsen. The alternative installation of sewage tanks which require emptying by tanker would further increase road traffic volumes.

It is also my understanding that national planning guidance has not been followed by CDC which should have consulted with Loxwood Parish Council in putting together its draft Local Plan.

I strongly object to Chichester District Council ("CDC") Local Plan proposal.

As a resident of Loxwood since 2014, I have seen continual pressure on the village and surrounding area to take more housing. Now CDC is requiring Loxwood to take a further 125 houses between 2019 and 2035. Allowing for some further housing on small windfall sites, it will mean more than 200 houses will be added to the village in less than 20 years.

I have two key points I want to raise as my objection to this Local Plan proposal by CDC.

Firstly the content of the Local Plan is not sound.

National Planning Policy Framework (NPPF) part 2 requires that Local Plans and planning applications deliver sustainable development. However this is not the case in Loxwood. Why ?

* Southern Water has stated that Loxwood Sewage Infrastructure has no more capacity AND does not have plans to upgrade the infrastructure in its 2020-2025 spending plans ! We already will be affected by the extent of new housing at Alford and the even bigger new town to be developed at Dunsfold !

* Loxwood has no viable public transport system. Only one bus a day to Guildford !

* Loxwood does not have any employment opportunities, residents have to commute to work by road !

* Parts of Loxwood are already prone to fluvial and surface water flooding !

* Loxwood has little demand for open market housing. Most houses are bought by people moving from elsewhere for a variety of reasons

125 new houses do NOT meet the sustainability tests defined in the draft Local Plan and therefore the plan can not be considered to be Sound as defined in the NPPF.

My second objection is that CDC has NOT followed proper and prescribed due process.

National planning guidance makes it quite clear that district councils should carry out "desktop" studies of potential housing sites and then consult !

However CDC has allocated 125 houses driven by developers who proposed sites when CDC asked for them ! Kirdford and Plaistow/Ifold have not been allocated any new houses and Wisborough Green just 25 houses !!

In the existing Local Plan, Loxwood, Kirdford and Plaistow/Ifold we're allocated 60 houses each. No parish consultation took place about site allocations and no effort has been made to share the housing burden across the three parishes defined by CDC as "Service Villages".

I would like to record my strong frustrations and anger with how CDC has approached this matter. There should be an immediate and total stop in any further planning proposals for housing to the area until proper process and checks have been undertaken.

See attachment

See attachment

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Horsham District Council welcomes the opportunity to comment on the Regulation 18 Draft "Preferred Approach" version of the Chichester Local Plan. Our comments focus on Policy S3 "Development Strategy"; Policy S4 "Meeting Housing Needs"; Policy S5 "Parish Housing Requirements 2016-2035"; Policy S7 "Meeting Gypsies, Travellers and Travelling Showpeople Needs"; Policy S8 "Meeting Employment Land Needs" and "Strategic Site Allocations".

Policy S3 Development Strategy/ Policy S4: Meeting Housing Needs
Policy S4 deals with meeting housing needs in Chichester District between 2016 and 2035. Policy S4 states that Chichester will provide for at least 12,350 dwellings between 2016 and 2035. This equates to an annual target of 650 dwellings per year, which is slightly in excess of the current identified housing target of 609 dwellings per year, as set by the Government. Horsham District Council therefore supports strategic policy S4, as it seeks to meet the full identified housing need in Chichester District.

We do, however, have concerns over the "Proposed Strategic Locations/Allocations" target of 4,400, which is set set out in the table in Policy S4. Policy S3 "Development Strategy" sets out the 14 proposed strategic development locations for Chichester District, which would make up the total strategic allocations target of 4,400 dwellings from Policy S4. Further detail on these individual sites is provided in the "Strategic Site Allocations" section of the draft plan (pages 95-133). First, the total number of dwellings identified in the strategic development
locations in Policy S3 is 8,085. This number is significantly in excess of the 4,400 identified in Policy S4 and no explanation is given as to why the numbers differ. Second, the 14 strategic development locations identified in Policy S3 include 5 neighbourhood plan 'housing allocations' (totalling 2,550 dwellings). These are Policy AL8 East Wittering (350 dwellings); Policy AL9 Fishbourne (250 dwellings); Policy AL10 Hambrook (500 dwellings); Policy AL11 Hunston (200 dwellings) and Policy AL13 Southbourne (1,250 dwellings). Horsham Council would like to see further evidence that this number of neighbourhood plan sites can realistically be delivered within the identified timescales, given the inherent difficulties of both "making" neighbourhood plans and bringing forward development sites within these neighbourhood plans.

In addition to meeting Chichester's identified needs, Horsham Council notes and welcomes the reference in paragraph 4.23 to the West Sussex and Greater Brighton Strategic Planning Board, and attempting to address the objectively assessed housing and other development needs within the wider West Sussex and Greater Brighton area. Horsham District Council considers it important that all districts and boroughs within the Strategic Planning Board area work together to aim to meet as much of the longer term and unmet development needs of the wider sub-region as possible, through an accelerated work programme of Local Strategic Statement 3.

Policy S5 "Parish Housing Requirements"
Horsham Council notes and supports Policy S5, which allocates parish housing requirements for small sites between 2016 and 2035.

Policy S7 "Meeting Gypsies, Traveller and Travelling Showpeople Needs"
Horsham Council notes and supports Policy S7, which identifies a need for 91 additional permanent residential Gypsy & Traveller pitches and 28 additional plots for Travelling Showpeople, and states that where there is a shortfall in provision, a Site Allocation DPD will be prepared to allocate sites.

Policy S8 "Meeting Employment Land Needs"
Horsham Council notes and supports Policy S8, which sets out the identified employment floorspace requirement for 2016-2035 (231,835 sqm) and which seeks to meet it through an identified supply of 235,182 sqm.
I trust these comments are helpful. Horsham Council is keen to work with Chichester District Council in taking the Chichester Local Plan through to adoption.

We object to the allocation site at Highgrove Farm, Bosham with approximately 13 ha of open countryside allocated to a minimum of 250 houses.

This development in the countryside directly conflicts with policy S24 Countryside and Policy S26 the Natural Environment; which clearly states there should be no adverse impact on the openness of views in and around the coast, designated environmental areas (i.e. the AONB) and the setting of the South Downs National Park. The proposed development at Highgrove Farm directly contradicts these policies.

We strongly believe that this development would cause irretrievable harm to the landscape character, setting and context of Chichester Harbour AONB and the intervisibility with the South Downs National Park. We feel that the measures proposed within the policy would not be able to sufficiently mitigate for the damage this development would cause.

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S4:
Loxwood is identified by the draft Plan as a larger service village. At Paragraph 3.16 the draft Plan states that its role as a service village should be developed and that the village has wider development potential. In view of this the Local Plan allocates Loxwood to provide 125 dwellings over the plan period. Whilst we support this Policy and approach in relation to Loxwood we consider that this figure should be increased to be consistent with similar or smaller sized villages in the District.
Increase the level of housing identified in Loxwood in line with similar or smaller sized villages within the District.

S5:
We object to Policy Reference S5 on the basis that it leaves a significant degree of housing to be identified through Neighbourhood plans including 125 dwellings at Loxwood. It is considered that the Local Plan review therefore fails to have been positively prepared as it should take a more direct approach to allocating sites particularly for the larger villages where a significant amount of housing has been planned (such as at Loxwood).
The total number of dwellings that the Council relies upon for delivery by neighbourhood Plans would be approximately 3,050, this includes 200 dwellings at Hunston, 1,250 dwellings at Southbourne, 250 dwellings at Fishbourne, 500 dwellings at Chidham and Hambrook, 350 dwellings at East Wittering/Brackleshamm, 500 dwellings to be delivered through 'nonstrategic' Neighbourhood Plans (including 125 dwellings at Loxwood). In total this would mean that over 24% of the Council's future housing land supply would need to be accounted for by Neighbourhood Plans. It is our view that this is not an
appropriate strategy to deliver the significant amount of housing required within the District particularly taking into account the long standing infrastructure constraints for the delivery of housing and the requisite shortfall in the delivery of housing sites.
Should Neighbourhood Plans not be forthcoming within 6 months Policy S5 suggests that the District Council will then take on responsibility for allocating sites.
In many cases, we are aware that a number of Parish Councils will be objecting to this consultation and the suggested delivery of housing within their area. Therefore it is unlikely that all Parish Council's will respond positively to this process, particularly where they already have a recently made Neighbourhood Plan. Therefore it is considered that this approach to the delivery of housing would not be effective. Ultimately, we consider that it would require a further Local Plan review (or an additional allocations DPD) and lead to uncertainty for local residents and delays to meet the urgent need for housing within the District.
With respect to the above we note that the Council's July 2018 Local Development Scheme indicates that they expect to begin work on a Site Allocations DPD in September 2020 with adoption anticipated in Summer 2022. This would be a further 3-4 year delay in ensuring that smaller settlements within Chichester are delivering a sufficient supply of dwellings to meet housing needs.
Whilst the Inspector in part agreed with this approach when considering the previous Local Plan, this was on the basis that Neighbourhood Plans would be forthcoming and would be built from work carried out on the Local Plan. However, in many cases, relevant Neighbourhood Plans have now been made and will no longer be based on the latest background studies, or indeed the Local Plan itself once it has been adopted. Furthermore, having gone through the process of producing Neighbourhood Plan's only very recently, many Parish Council's will not have the desire or resources to review these immediately to allocate the level of housing identified in the plan.
The Inspector also thought that this approach was acceptable because at the time the Council were progressing a small housing site allocation DPD. This DPD has now been adopted and in reality has delivered on a small amount of sites which have not contributed significantly to the housing supply position. It is considered that it would not be appropriate to wait to deliver such sites through a further DPD, or a further Local Plan review as it will only result in continued delays and uncertainty over the delivery of housing.
Further to the above it is noted that the Council has relatively recently lost appeals on the basis that they are not able to provide a 5-year housing supply. The last of these being in late 2017. Since then Appeals have been found in favour of the Council but in any case It is clear that the Council's 5-year housing land supply has been tenuous at best and relies on interpretation of the deliverability and progress of approved schemes.
Considering the long standing and identified shortfall of housing in Chichester it is
considered that leaving such a significant amount of housing for delivery through
Neighbourhood Plans is inappropriate particularly bearing in mind that a number of Parish Councils have only recently made Neighbourhood Plans and have not begun any formal review process.
Therefore it is considered that the Council should be more pro-active in identifying
appropriate sites or general locations for housing to ensure that the required infrastructure can be delivered at the appropriate stage and the deliverability of sites can be secured.
The Local Plan should allocate suitable land for development, such as land at Hawthorne Cottage, Loxwood. This land is suitable, available and achievable as identified by the Chichester Housing and Economic Land Availability Assessment (under reference HLX0003). It is considered that the site is well related to existing development within Loxwood and would be able to accommodate houses in a sustainable manner.

S5:
We object to Policy Reference S5 on the basis that it requires a significant level of housing to be provided through Neighbourhood plans including 200 dwellings at Hunston. It is considered that the Local Plan review therefore fails to have been positively prepared as it should take a more direct approach to allocating sites, particularly for the larger villages. In many cases, we are aware that a number of Parish Councils (including Hunston Parish Council) will be objecting to this consultation and the suggested delivery of housing within their area. Therefore it is unlikely that all Parish Council's will respond positively to this process creating delays and uncertainty for local communities.
Considering the long standing shortfall of housing in Chichester it is considered that leaving such a significant amount of housing for delivery through Neighbourhood Plans is inappropriate. Therefore it is considered that the Council should be more pro-active in identifying sites for housing.
The Local Plan should identify sites or locations that the Council consider to be suitable for housing, including land at Reedbridge Farm which is considered to be suitable, available and achievable to deliver housing.

AL11:
The proposed policy sets out detailed policy requirements without identifying the site or location which has been considered suitable for the proposed strategic site. It is considered that the Neighbourhood Plan process is not suitable to identify strategic level sites and that these should be identified through the Local Plan review.

The Local Plan should allocate suitable land for development, such as land at Reedbridge Farm, Hunston. This land is suitable, available and achievable as identified by the Chichester Housing and Economic Land Availability Assessment.
Furthermore the documentation we have provided to the Council demonstrates an
achievable scheme that would make a significant contribution towards the number of
dwellings allocated within Hunston in a sustainable manner that would achieve the Policy requirements set out by AL11.

I would like to make the following points in response to the consultation on the CDC local Plan Review, specifically to the proposal to build an additional 50 homes in Boxgrove.

1. CDC Policy DM22 states that "Development in rural areas must meet a demonstrated need".

Where is the need for 50 additional homes in Boxgrove evidenced or demonstrated?

2. CDC's Policy S5 "Parish Housing Requirements" states that "it is intended that identification of sites will be determined by local communities through Neighbourhood Planning, in consultation with the Council" .

The Boxgrove Neighbourhood Plan has not yet been determined, has been the subject of many delays for a variety of reasons of which CDC will be well aware, and is currently in limbo whilst CDC decide and advise on the next stages. It would therefore seem to be undemocratic were CDC to impose this housing upon the village prior to the Neighbourhood Plan being finalised.

3. The National Planning Policy Framework (NPPF) confirms a presumption in favour of development, but also states that "new development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment wherever it occurs".

Building the proposed additional 50 houses in Boxgrove in the next five years will detrimentally affect the distinctive character of this small, quiet village; adversely impact upon existing, residents through increased noise pollution; put the safety of existing residents at risk through increased air pollution as a result of the additional traffic; and compromise the safety of residents and others by increasing traffic at various points on the highway, not the least of which would be the likely egress to and from the mooted development site.

4. Further, CDC's Policy DM3, on Housing Density, states "All new housing will be developed at a density that is consistent with making the best use of land whilst achieving high quality, sustainable design that does not compromise the distinctive character of the area in which it is located."

Boxgrove's existing population is just over 900. Building a further 50 homes (which I understand will result in 115 new homes over the 10year period) would be a considerable Increase on the existing housing provision, lmpacting directly and adversely upon the distinctive character of this small and ancient village.

5. In the local Plan Review, CDC's Development Strategy stated at Paragraph 4.14 is that "the starting point for housing development in villages is that in principle, they are suitable places to accommodate new housing. However, consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth, including infrastructure capacity, the existence of suitable sites and consultation responses."

Boxgrove lacks the required Infrastructure capacity and the proposed site (at a recent Parish Council Meeting mentioned as west of Priors Acre and south of Crouch Cross Lane) has no adequate or safe access for road traffic.

6. In Part 2 of the Local Plan Review, Preferred Approach, Development Management, paragraph 7.44 states that "It is important that local services and community facilities aimed at meeting doily needs ore available where people live, including in smaller towns and villages in order to minimise the need to travel"'.

Also, in the Local Plan Review, Spatial Strategy, paragraph 4.80 states that "The provision of infrastructure is necessary to support development. It can range from strategic provision, such as the provision of a new road or school........to improvements to telecommunications. A key element of the Local Plan Review is for new development to be coordinated with the infrastructure it requires and to take into account the capacity of existing infrastructure."

Boxgrove has neither Post Office, Bank, doctor's surgery, nor dentist.
The Primary School is currently at capacity and has no room for expansion; there is no secondary school.
It is not possible to access superfast Broadband in Boxgrove.
The bus service does not operate in the evening, so shift workers or anyone wishing to go beyond the village for entertainment must use their own transport or a taxi service. Boxgrove is already lacking in the required infrastructure without adding the extra 50 houses proposed in the Plan Review.


7. Paragraph 7.48 of the Local Plan Review states that "it is necessary to consider the impact of any new development upon the existing transport network; highway safety; and current provision for movement for all modes of transport"'.

Further, CDC Policy DM8: Transport, states that development must provide for the access and transport demands they create, through provision of necessary improvements to transport networks, services and facilities; also that development is located and designed to minimise additional traffic generation and movement and should not create or add to problems of highway safety, congestion, air pollution or other damage to the environment. Development must not create residual severe cumulative impacts on surrounding areas; and that the proposal has safe and adequate means of access and internal circulation/turning arrangement for all modes of transport relevant to the proposal.

The provision of a further 50 homes in Boxgrove - in addition to those already planned, taking the total to 115 over 5-10 years - will create extra traffic on the roads in and through the village, the surrounding countryside, and on the A27. It is already extremely difficult and dangerous at peak hours to access the A27 from the village, at the Tangmere roundabout. The current congestion problems of the A27 are well documented. No further development along the A27 corridors should be planned without addressing the basic need to resolve the congestion on the A27.
Further, if the proposed site is indeed (as I understand from the Parish Council meeting discussions) west of Priors Acre and south of Crouch Cross lane, there will be significant safety and access issues. Priors Acre access is restricted and cannot sustain more traffic, having had 26 new homes added to the existing development there, with egress shared from Priors Acre and a farm track.
Finally, the bus service is inadequate in the evenings and residential traffic would increase through the village.

8. CDC Policy DM 29: Biodiversity, states "Planning permission will be granted where it can be demonstrated that (5} any individual or cumulative adverse impacts on sites are avoided". Building an additional 50 houses behind Priors Acre (if that Is the proposed site) will have a cumulative adverse impact upon the natural habitat of a large number of wildlife. The introduction of a "wildlife buffer zone" would be helpful, but will not provide sufficient shelter or nesting sites for the diverse species of birds which currently exist in the Immediate area; nor Is it likely to prove sufficient for the hedgehogs which currently forage In the farm paddocks. Bats will have their foraging territory reduced too - once housing is created around the "buffer zones"' the bats encounter too much light from people using their gardens in the evening and will not confine themselves to a "wildlife corridor" but will instead vacate the area.

In summary, building an additional 50 houses in Boxgrove (culminating in a total of 115 new homes over the period of the Plan) will be detrimental to the village environment, the resident population and to local biodiversity; it will add to the existing infrastructure problems, particularly the A27 and the A285; and does not meet a proven need.

I ask that my points be taken into consideration during the Local Plan Review Consultation Process.

I wish to strongly object to the proposed increase in housing as outlined in the Draft Local Plan.

* Loxwood sewage infrastructure has no more capacity to such an extent that holding tanks have had to be installed on the new nursery site .
* Loxwood is prone to surface water flooding
* There are no employment opportunities in the local area, therefore the traffic on the roads will vastly increase.
* Loxwood does not have a public transport system- not even linking it to local railway stations.
* The village school is already full to capacity.
* Loxwood surgery would be more than stretched with such a large increase in population.

Not withstanding the above, it is clear that any increase in housing is a breach of the Loxwood Neighbourhood plan agreed by Chichester Council (and upheld by a Court of appeal when development was attempted on site known as HLX0007 in the High Street.)

The proposed developments for Loxwood are excessive when comparing planned numbers for new properties in Plaistow, Kirdford & Wisborough Green- Loxwood seems to risk becoming vulnerable to uncontrolled future development.

The desire for new developments already seems to be waning with fliers offering discounts, free stamp duty and furniture awards being posted locally!

Just because landowners are prepared to sell land to builders/developers does not mean that the Council should rubber stamp approval for a requirement that is out of place and not now required.

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I am writing to object to CDC's proposals in its new Local Plan to allow developers to build at least another 125 houses in the village of Loxwood.

In the existing Local Plan I understood that Loxwood, Kirdford and Wisborough Green were each allocated 60 houses which seemed a more sustainable and fairer distribution economically, socially and environmentally between these three Service Villages.

I lived near the village of Plaistow for 55 years and only moved to Loxwood less then four years ago. I know the area well and considered carefully the Loxwood Neighbourhood Plan before buying my current property. It is very worrying to think that this semi rural village may now be subjected to over development which if not controlled and managed properly could cause significant problems for the community in the future and effect the quality of residents lives.

My principal reasons for objecting are;

* The sewage system is already inadequate and causes problems for some
residents.

* The B2133 and Station Road are extremely busy roads used by commuters as well as local people. The number of Lorries and cars driving through the village is continually increasing.

* Despite a 30 mile speed limit through the centre of the village Loxwood is becoming a more dangerous place for pedestrians to walk round.

* Parking outside the local shop/post office, butcher and hairdressers is very
inadequate and dangerous. Parked vehicles frequently obstruct visibility.

I object to the housing allocation of 125 new builds to Loxwood under the above plan for the following reasons:

- The sewerage system is unable to handle any increases in demand.
- The local school is unable to handle an increase in puil numbers due to lack of funding.
- No public transport to support an external increase in Loxwood population.
- Traffic from developments already under construction or planned at Alford, Billingshurst, Dunsfold will overload an already very busy thoroughfare.
- No effort by CDC to spread load for new buildings to other villages.
- CDC is inconsistent by refusing permission for developments in other sites, eg. Foxbridge Lane.

From the above I am of the opinion the referred draft is unsustainable and I confirm my objection.

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As two people in our 90s, my wife and I object most strongly to your draft Local Plan as it affects Loxwood, on grounds of lack of soundness and of the process adopted by your department,

With regard to the former the proposed developments are not sustainable because:-

1) The village infrastructure is inadequate, particularly the wastewater system which is up to full capacity with no prospect of improvement (the Loxwood Green development has to rely on holding tanks that need emptying by tanker.); there is virtually no public transport. only a derisory Bus service; the A281 is overloaded, especially in rush-hours on the approaches to Guildford.

2) Loxwood does not have any significant employment opportunities so residents must commute to work by road. There is little demand for open-market housing and the need for local and affordable housing would easily be met by the present Neighbourhood Plan.

As regards the process by which you have arrived at the Draft Local Plan we submit that the figure of 125 new houses is unfair and vastly excessive and the allocation has been driven by developers instead of the planning authority. Kirdford and Plaistow/lfold have not been allocated any new houses and Wisborough Green only 25.

No parish consultations took place about site allocations and CDC has not followed national guidance in developing the draft local plan.

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