1.23

It needs to be clearer what has been agreed in respect of the Statement of Common Ground. It also needs to be clearer whether neighbouring authorities will be able to meet any unmet demands. The council should optimise housing delivery especially where these areas are geographically close to the SDNP.

Whilst it is clear that the local authorities have established a joint working approach, it is not clear what has been agreed in the respective Statement of Common Grounds. Paragraph 5.2 of the draft Local Plan states that the district is unable to meet SDNP unmet need, however it is not clear if neighbouring authorities will be able to meet any unment demand. we therefore consider that this is another reason why in order to be considered to be positively prepared and effective, the Council should be optimising housing delivery especially where these areas are geographically close to SDNP.

Support – with qualification
Please refer to the attached document.

See submitted letter
The housing number should be increased as there appears to be additional capacity on the A27 beyond that stated
Additional sites that are currently in the planning system without technical problems and recommended by officers for planning permission should be allocated in the Local Plan to meet the housing need
There needs to be more certainty on what happens if Neighbourhood Plans and the District Council do not deliver the housing numbers expected in a timely manner
Policies NE3 and NE4 need to be amended

Please see submitted letter but we do not believe the housing number has been robustly evidenced as we believe the housing requirement could be higher and more sites should be allocated and provided for and we do not believe the Duty to Cooperate has been met.

The Council should re-visit its discussions with neighbouring authorities.

2.2 Section 110 of the Localism Act 2011 sets out the ‘duty to co-operate’. This requires Local Planning Authorities, County Councils and a number of other public bodies to co-operate in relation to strategic cross-boundary matters in the preparation of Development Plans.

2.3 The NPPF (2021) confirms in paragraphs 24 – 27 that LPA’s have a duty to cooperate with each other and other prescribed bodies on a range of cross-boundary strategic issues in an effective and continuous manner.

2.4 In terms of the strategic matters, Planning Policy Guidance clarifies that this is a duty to discuss and not a duty to agree. However, LPA’s should make the effort in seeking and securing necessary cooperation on cross-boundary issues.

2.5 The consultation is supported by a Duty to Cooperate Statement of Compliance (January 2023), which summarises engagement undertaken up to the point of the Regulation 19 consultation with relevant bodies, including neighbouring authorities.

2.6 In respect of neighbouring authorities, these comprise:

• Arun District Council (ADC);
• East Hampshire District Council (EHDC);
• Havant Borough Council (HBC);
• Horsham District Council (HDC);
• South Downs National Park Authority (SDNPA); and
• Waverley Borough Council (WBC)

2.7 All are at various stages of Plan-making.

2.8 Whilst the Council has demonstrated ongoing engagement with the referenced authorities and other relevant bodies, we are concerned that the Plan strategy, specifically the ‘constrained’ housing requirement figure, has focused some of these conversations with neighbouring authorities on meeting Chichester’s unmet need rather than the ability of Chichester to meet the unmet need of those authorities, most notably the South Downs National Park.

2.9 This is backwards step from the Preferred Approaches consultation (December 2018) which sought to address an element of unmet need through agreement with South Downs National Park.

2.10 As detailed below, we consider there is no justified rationale for a suppressed housing requirement figure and the Council should re-visit its discussions with neighbouring authorities, particular the South Downs National Park, to understand any unmet need which can be accommodated within Chichester District.

The ‘tests of soundness’ for Local Plan preparation are set out in paragraph 35 of the July 2021 NPPF. They require the 2021-39 Local Plan to have been:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

Local Plan reviews are a legal requirement every 5 years in accordance with Regulation 10A of the 2012 Town and Country Planning (Local Planning) (England) Regulations. The Regulation 19 Plan is not legally compliant as it has not been reviewed within 5 years of the last Plan adopted in July 2015. It is also disappointing that the failure of the current Regulation 19 Local Plan to meet objectively assessed need (OAN) of 638 dpa outside the national park has not been properly evidenced in any up to date statement of common ground with neighbouring authorities with regards to the ‘duty to cooperate’.

At this stage we believe the Plan as drafted therefore fails the positively prepared, effective, and consistent with national planning policy tests.

Duty to Cooperate

The 2014-2029 Local Plan adopted in 2015 does not meet the full objectively assessed housing needs for the area. But it did recognise that future proposals to improve the capacity of the A27 and wastewater treatment works could facilitate additional housing growth. For this reason, it committed the Council to a review of the Plan within five years to ensure that housing needs could be met. That undertaking to review within 5 years was not met.

In 2021 the Council invited an advisory visit from PINS to advise on how the present Local Plan should be prepared. The inspector advised that if the Plan was prepared which did not meet the full housing needs of the area, it would have to show that it had followed the duty to co-operate with neighbouring authorities in maximising the effectiveness of plan preparation.

The inspector said the Duty to Cooperate was therefore critical in the preparation of the Local Plan Review. At the time of the meeting, the council said discussions with neighbouring authorities had been carried out on the basis that the Local Plan Review would meet the full objectively assessed housing needs (OAN) for the area. However if this was not the case, the inspector said evidence of constructive, active, and on-going engagement to determine whether or not development needs could be met elsewhere would need to be shown. Importantly, the inspector said,1) ‘a failure to meet the Duty to Cooperate cannot be remedied during the examination process because it applies to the preparation of the Plan, which ends upon submission’, and 2) local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before submitting plans for examination.

The Duty to Cooperate Statement of Compliance (January 2023) forms part of the evidence base for the Submission Local Plan. In the event, the Local Plan excluding the national park only provides for 575 dpa against an OAN of 638 dpa. However this under provision against need has not been justified anywhere in discussions with neighbouring authorities before the Plan was submitted. Appendix 1 of the Statement of Compliance lists those authorities that were consulted during the earlier Regulation 18 Preferred Approach consultation. Appendix 2 lists those authorities where Statements of Common Ground have been agreed with Chichester DC for the Regulation Submission 19 Plan. No statements have produced or agreed. Therefore as it stands the under provision of housing against OAN in the Plan has not been justified. The failure to meet the duty to cooperate cannot be remedied because it has already ended with the Submission Plan. The plan therefore fails the positively prepared and justified tests. It also fails to comply with national policy in the NPPF paragraph 24-27 which advises on the duty to cooperate approach.

Local Plan Policies

The remainder of these comments deal with the proposed Settlement Hierarchy - policy S2, policy H1 – Meeting Housing Need, Non-Strategic Housing Sites – Policy H3 and T1 Transport Infrastructure.

Policy S2 – Settlement Hierarchy
The Settlement Hierarchy background paper prepared for the Regulation 18 draft Local Plan provides the justification for the hierarchy in Policy S2 of the Regulation 19 Local Plan. We agree that Plaistow & Ifold has been properly identified as a service village in the settlement hierarchy.

Policy H1 – Meeting Housing Needs
The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
We have already explained why the failure of the Council to plan for the 638 dpa in the Regulation 19 Local Plan has not been justified in connection with the duty to cooperate and no evidence has been presented in any statement of common ground with neighbouring authorities to show how development needs could be met elsewhere.
We note from policy H1 that the components of housing supply include outstanding housing commitments without planning permission from the 2015 adopted Local Plan, the Site Allocations DPD, and ‘made’ Neighbourhood Pans.
However, it is unclear how the above housing supply components have been calculated and how they have translated into the strategic and non-strategic allocations in policies H2 and H3.
In the case of Plaistow and Ifold, the last adopted 2015 Local Plan identified the settlement with an allocation of 10 dwellings. The subsequent Site Allocation DPD identified land north of Little Springfield Farm for 10 no. units. A Neighbourhood Plan for Plaistow and Ifold was produced but was withdrawn and no site allocations were confirmed. The allocated site north of Little Springfield Farm remains undeveloped.
With specific reference to Plaistow & Ifold we would therefore query whether 1) the existing housing commitments without planning permission in the 2015 Local Plan and the Site Allocations DPD have been double counted, and 2) whether the non-implementation of the 10 units from the 2015 Local Plan have been ring fenced to count against the new proposed allocation of 25 dwellings at the settlement? In which case, we would question why a further 15 dwellings are only proposed at a service village in the hierarchy compared to other service villages in the NE part of the district which are proposed for higher levels of development (Loxwood 220 dwellings, Kirdford 50 dwellings and Wisborough Green 75 dwellings).
If the 25 dwelling allocation at Plaistow & Ifold is intended to be additional to the 10 units identified in the last 2015 Local Plan, then the allocation should be increased to 35 dwellings as a minimum to reflect the non-implementation of the 2015 allocation.
Policy H3 – Non-Strategic Parish Allocations
Policy H3 identifies non-strategic parish allocations. We have explained above our queries with the 25 dwelling allocation to Plaistow & Ifold, whether it has allowed for the non-implementation of the 10 units in the last 2015 Plan and why it compares so unfavourably with much higher levels of development for the other service villages in the NE part of the district.
We would also query why the options outlined in the PINS advisory visit of 2021 have not been more thoroughly tested for increased housing provision in the north part of the district to increase the supply of housing to meet OAN. There is no updated Settlement Hierarchy background paper, and the revised housing distribution has not been justified anywhere in the evidence base for the Regulation 19 Local Plan.

Policy T1 – Transport Infrastructure
The policy objectives to ensure new development is well located and designed to avoid or minimise the need for travel and encourage the use of sustainable modes of travel as an alternative to the private car are supported. However, the proposed contribution of £7.7k per dwelling towards A27 highway improvements applies to new housing across the district even in the NE part of the district where impacts from development on the A27 will be less than developments in the south of the district.
In any event it is unclear how the contributions are justified when the responsibility for trunk road infrastructure improvements rests with National Highways.
The proposed contribution in T1 is therefore questioned and in our view, flawed. The level of contribution set out in the policy and the principle of a contribution will therefore require further testing at the forthcoming Examination.

The ‘tests of soundness’ for Local Plan preparation are set out in paragraph 35 of the July 2021 NPPF. They require the 2021-39 Local Plan to have been:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
Local Plan reviews are a legal requirement every 5 years in accordance with Regulation 10A of the 2012 Town and Country Planning (Local Planning) (England) Regulations. The Regulation 19 Plan is not legally compliant as it has not been reviewed within 5 years of the last Plan adopted in July 2015. It is also disappointing that the failure of the current Regulation 19 Local Plan to meet objectively assessed need (OAN) of 638 dpa outside the national park has not been properly evidenced in any up to date statement of common ground with neighbouring authorities with regards to the ‘duty to cooperate’.

At this stage we believe the Plan as drafted therefore fails the ‘positively prepared’, ‘effective’, and ‘consistent with national policy’ tests.

In addition, with regard to the longer term growth requirements and the singular issue of a potential new settlement the plan also fails the ‘justified’ and ‘consistent with national policy’ tests of soundness.

Duty to Cooperate
The 2014-2029 Local Plan adopted in 2015 does not meet the full objectively assessed housing needs for the area. But it did recognise that future proposals to improve the capacity of the A27 and wastewater treatment works could facilitate additional housing growth. For this reason, it committed the Council to a review of the Plan within five years to ensure that housing needs could be met. That undertaking to review within 5 years was not met.

In 2021 the Council invited an advisory visit from PINS to advise on how the present Local Plan should be prepared. The inspector advised that if the Plan was prepared which did not meet the full housing needs of the area, it would have to show that it had followed the duty to co-operate with neighbouring authorities in maximising the effectiveness of plan preparation.

The inspector said the Duty to Cooperate was therefore critical in the preparation of the Local Plan Review. At the time of the meeting, the council said discussions with neighbouring authorities had been carried out on the basis that the Local Plan Review would meet the full objectively assessed housing needs (OAN) for the area. However if this was not the case, the inspector said evidence of constructive, active, and on-going engagement to determine whether or not development needs could be met elsewhere would need to be shown. Importantly, the inspector said,1) ‘a failure to meet the Duty to Cooperate cannot be remedied during the examination process because it applies to the preparation of the Plan, which ends upon submission’, and 2) local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before submitting plans for examination.

The Duty to Cooperate Statement of Compliance (January 2023) forms part of the evidence base for the Submission Local Plan. In the event, the Local Plan excluding the national park only provides for 575 dpa against an OAN of 638 dpa. However this under provision against need has not been justified anywhere in discussions with neighbouring authorities before the Plan was submitted. Appendix 1 of the Statement of Compliance lists those authorities that were consulted during the earlier Regulation 18 Preferred Approach consultation. Appendix 2 lists those authorities where Statements of Common Ground have been agreed with Chichester DC for the Regulation Submission 19 Plan. No statements have produced or agreed. Therefore as it stands the under provision of housing against OAN in the Plan has not been justified. The failure to meet the duty to cooperate cannot be remedied because it has already ended with the Submission Plan. The plan therefore fails the positively prepared and justified tests. It also fails to comply with national policy in the NPPF paragraph 24-27 which advises on the duty to cooperate approach.

Local Plan Policies
The remainder of these comments deal with the Settlement Hierarchy policy S2, H1, H2 H3 and H8.

Policy S2 – Settlement Hierarchy
The Settlement Hierarchy background paper prepared for the Regulation 18 draft Local Plan provides the justification for the hierarchy in Policy S2 of the Regulation 19 Local Plan. We agree that the hierarchy prioritising development at Chichester as the sub regional centre, followed by development at the settlement hubs, service villages and the rest of the plan area is reasonable. However, although the distribution of housing amongst the settlements in the current Regulation 19 plan has been updated compared to the last Regulation 18 plan, the background paper itself has not been updated. Nor is there any justification or explanation for the change in the quantum of strategic and non-strategic housing to the different categories of settlement in the background paper or the Local Plan itself.

Policy H1 – Meeting Housing Needs
The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
We have already explained why the failure of the Council to plan for the 638 dpa in the Regulation 19 Local Plan has not been justified in connection with the duty to cooperate and no evidence has been presented in any statement of common ground with neighbouring authorities to show how development needs could be met elsewhere.
Policy H2 – Strategic Site Allocations and Policy H3 – Non-Strategic Parish Allocations
Policy H2 identifies strategic scale and policy H3, non-strategic allocations. We have explained above that the Settlement Hierarchy Background Paper was prepared for the 2018 Preferred Options Regulation 18 Local Plan but has not been updated to provide any justification for the revised housing distribution and quantum of development for the named locations and settlements in the Regulation 19 Local Plan.
Policy H8 – Specialist accommodation for Older People
National policy in the online planning practice guidance (PPG) is clear that the need to provide housing for older people is critical. The guidance on the provision of this type of housing states:
• Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require.
• They could provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period.
• It includes the following within the general definition of specialist housing - age-restricted general market housing, retirement living or sheltered housing, extra care housing or housing-with-care, residential care homes and nursing homes, and senior co-housing communities.
• LPA’s can identify sites for co -housing communities and other specialist housing types for older people, because,
• Allocating sites can provide greater certainty for developers and encourage the provision of sites in suitable locations. This may be appropriate where there is an identified unmet need for specialist housing. The location of housing is a key consideration for older people who may be considering whether to move (including moving to more suitable forms of accommodation).

Factors to consider include the proximity of sites to good public transport, local amenities, health services and town centres.
In our view however, draft Policy H8 doesn’t reflect the guidance in the PPG. For instance, although the policy sets out a threshold of provision for specialist housing of housing sites of 200 or more units, there is no guidance on the actual % provision as there is for example, on affordable housing. All it says is the specific type and amount of accommodation required will depend on the size and location of the site.
The supply of specialist housing should not just be focused on large scale housing schemes. The landscape and environmental constraints across the district even outside the national park would not necessarily allow for large 200 plus unit schemes in all locations. To support an ageing population policy should support the provision of suitable specialist housing to meet the differing needs of individuals across a range of options and in a range of locations.
The second part of H8 should therefore confirm that proposals for specialist housing, such as homes for older people will be supported without any policy qualification for a site’s location within or outside a settlement boundary or within an AONB where a proposal in its local context is not deemed to represent major development.
Rather than rely on the criteria based approach, the policy should also allow for the allocation of sites for specialist accommodation for older people in a Neighbourhood Plan where a site has the support of local people.

See attached representation.

See attachment.

These comments are confined to the three areas set out in the consultation - Legal, Soundness and Duty to Cooperate and to two documents -the draft Local Plan and the Sustainability Assessment.

Legal Status
The Legal status of the Plan is proven but because of the protracted course of the plan's preparation some stages are now dated and raise the question that they should be refreshed.This is the particular case in respect of public participation.There have also been significant changes in legislation that guides the plan’s formulation that would have benefited from revised statement of legislative/legal context.

Soundness
In the SA it is stated that the key issue for the plan is the A27 and its capacity.This statement is fundamental in that it is realistically outside the scope of the local planning authorities (CDC and West Sussex CC) to have any direct control over.Unless National Highways position is changed from their previous statements on time scales and what might be included in their assessment no consideration of A27 will be made until RIS3 taking any even initial action into the next decade.
So fundamental and influential is the A27 that assessment of Local Housing Need (LHN),a key component of the whole plan, is reduced from 638 units pa to 535.This position must have an impact on the plan’s ‘Soundness and crucially the phasing of development.


It is worthy of note that three recent housing appeal decisions unfortunately focused primarily on the lack of a 5yr housing supply base on the 638 higher figure.More pressing were issues of sewage system capacity,coastal inundation and fluvial flooding and nutrient neutrality.

The reduction of housing requirements that the Reg19 LP now promotes is very welcomed.

The reduction on the Manhood PeninsulaIt appears to be derived because of recent housing approvals on appeal bringing forward housing that achieves the revised target based on the 535 figure .Two points arise none of theses sites are in locations that CDC indicated in documents such as the HELAA and SHELAA as positively sustainable and as all other significant Peninsula housing is dropped do these sites exceed what would have been planned totals.

The SA ‘Framework ’only addresses ‘Water- protection of resources’ this is highly appropriate given the problems experienced in the north eastern part of the district in the summer of 2022 and will become more pressing in the south.Resolution of this issue that stopped planning applications seems to be by reducing water usage at least to 110 ltr ppd or lower this is when Southern Water only hope to achieve 125ltr by 2050 .
Consideration in the framework should extend to the’ Water Cycle’ and particularly address the acute problems of sewage system network capacity, polluting WWTW outfalls,nutrient neutrality.These systems are already currently stressed/ completely overloaded with current levels of use without new development coming on stream and discharges of untreated sewage are a significant and growing problem to Chichester, Langston and Pagham Harbours- this situation must be set against Defra- Storm OverflowDischarge Reduction Plan’s statement “Protecting the Environment-water companies shall only be permitted to discharge from a storm overflow where they can demonstrate that there is no local ecological impact”. Damage to Chichester/ Langstone Harbours is documented by a daming Natural England report and by that expected for Pagham Harbour all the sites of national significance for biodiversity and protected habitats.
Whilst para 5.2.34 and Box 5.1of the SA summarise the position no direct statement of intervention is made.Reliance on a ‘Statement of Common Ground that is referred to offers no positive programme of future capital investment by Southern Water (SW) especially when set against SW’s overall regional programme its cost and priorities as set out in their draft DWMP-the final version of which is due for release in March this year- does the Plan reflect this documents information that is so crucial to supporting the infrastructure need for the scale of development envisaged is challenging to the plan’s ‘Soundness’

Time scale of the crucial improvements to infrastructure and particularly sewer and lWWTW capacity is of particular concern. SW’s Drainage and Wastewater Management Plan v1May 2020 set out in very comprehensive way what needs to achieved and indication of time scale -placing most in AMP8 the next 5 yr business cycle and OFWAT approval would be needed for the scale of expenditure that is many hundred of millions. These time scale constraints should be reflected in the phasing of any housing development that will have to utilise the network.There is no direct indication that such phasing will be actively enforced.

The lack of inclusion in a key background supporting document -Strategic Flood Risk Assessment (SFRA) -of the Planning Practice Guidance on Flood Risk and Coastal Change that has important bearing on issues particularly for the southern plan area and specifically mentions the importance of the phasing of development to infrastructure provision is a concern especially when it was published in August 2022.These omission again have an impact on the Plan’s overall ‘Soundness.

A significant consideration in the plan that supports the need for more housing supply is the need to address affordability.The district has one of the highest ratio of median earnings to house prices of 14 times and despite substantial house building during the period 2013 -2022 the ratio has increased from 10.55.It is clear that the type of housing that has occurred and continues to be proposed in the district has done little if anything to impact on affordability and address the need for social/lower cost housing.Based on the 2011 census the district experienced 1,505 inward migration( only Brighton and Hove being higher in the West Sussex/ Gt Brighton area) - this trend has been expected to have continued and accelerated as the pandemic increased the popularity of coastal property and raised market cost of property. Just building more houses without policy intervention to prioritise social shared ownership housing will most probably prove to further increase the extent of unaffordability with the resultant consequences on workforce -especially to support the district ageing population- and supporting young people to remain in the area they have grown up in or have come to be educated.This aspect is cause concern over the Plan’s ‘Soundness’.

Considerable emphasis is placed on the issues of nutrient neutrality,damage to biodiversity and pollution of Chichester Harbour AONB but such emphasis is not extended to Pagham Harbour that has a similar ecological status to Chichester and suffers the same degradation issues.
Although Pagham is outside of the nutrient protection zone the factors contributing to nutrient problems are apparent feeding into Pagham.The delayed report on condition for Pagham from Natural England mirroring that for Chichester Hb gives every indication it will indicate the same levels of detriment as those in Chichester Hb.This assumption being supported by condition reports for instance for rife and ditch condition known reports.Added to these factors are known issues relating to untreated discharges from Sidlesham WWTW.The Local Plans’s lack of affording Pagham similar consideration to Chichester Hb is an issue that impacts on the Local Plan’s overall ‘Soundness’.

Duty to cooperate
The West Sussex and Greater Brighton Strategic Planning Board (WSGBSPB) provides a context for integrated planning along the coast plain area.It is stated that this board is due to issue a review of its 2016 report next month -does the Plan address any issues that this review may raise? . Housing needs are a major feature of the area and the need to transfer unmet housing demand to adjoining authorities is characteristic feature of past policy..The SA quite categorically states that there would be no realistic potential to meet unmet housing need above the now established LHN figure. Should the WSGBSPB’s report signal the need for the district to absorb housing from other areas there may be problems as the Plan does not appear to offer any contingency or process how such pressure might be mitigated.
The highly restricted housing numbers in the South Downs National Park Local Plan and the closeness of its boundary to the ‘coastal strip’ are contributing factors to the area's carrying and overall capacity to support development. Further constraint is imposed by the Chichester Harbour Area of Outstanding Natural Beauty ( AONB) and the geographical physical restrictions of the Manhood Peninsula creating ‘coastal squeeze’.

See attachment.

Support – with qualification
Please refer to the attached document.