Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 4734

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This housing need shortfall is exacerbated by the fact that the Plan fails to take account of the full potential of all of the new strategic locations within the District, such as Boxgrove.
This strategic level of growth could amount to at least 200 homes, significantly greater than that proposed in Plan Policy H3, which states that, as a ‘service village’, 50 dwellings could ‘come forward through the neighbourhood planning process’. Paragraph 3.19, Page 38, of the Regulation 19 document cites some of the reasons for this limited growth within non-strategic Parishes, such as Boxgrove, as being:

• Land Availability.
• Landscape Considerations.
• Settlement Patterns.
• Available Infrastructure.

Indeed, there is an evidence base that supports the case that Boxgrove has the potential to accommodate a strategic level of housing growth, rather than the conclusion that it has limited capacity due to constraints – or the 50 homes proposed by CDC in Plan Policy H3.

The Housing Distribution Background Paper explains the development of the proposed distribution of housing and the split between strategic and non-strategic provision. The SA report (January 2023, Section 7), sets out the council’s reasoning for the preferred growth strategy having considered reasonable alternatives, including consideration of Boxgrove.

Object

Representation ID: 4737

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This housing need shortfall is exacerbated by the fact that the Plan fails to take account of the full potential of all of the new strategic locations within the District, such as Boxgrove. This strategic level of growth could amount to at least 200 homes, significantly greater than that proposed in Plan Policy H3, which states that, as a ‘service village’, 50 dwellings could ‘come forward through the neighbourhood planning process’. Paragraph 3.19, Page 38, of the Regulation 19 document cites some of the reasons for this limited growth within non-strategic Parishes, such as Boxgrove, as being:

• Land Availability.
• Landscape Considerations.
• Settlement Patterns.
• Available Infrastructure.

Indeed, there is an evidence base that supports the case that Boxgrove has the potential to accommodate a strategic level of housing growth, rather than the conclusion that it has limited capacity due to constraints – or the 50 homes proposed by CDC in Plan Policy H3.

The Housing Distribution Background Paper (May 2024) explains the development of the proposed distribution of housing and the split between strategic and non-strategic provision. The SA report (January 2023, Section 7, sets out the Council’s reasoning for the preferred growth strategy having considered reasonable alternatives, including consideration of Boxgrove

Object

Representation ID: 4741

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Currently the Plan proposes 10,354 total new homes over the Plan period (575.2 homes p.a). However, using the Standard methodology, the actual housing needed in the District is 11,484 homes. The 11,484 figure is calculated using data from the ICENI Chichester Housing and Economic Development Needs Assessment (HEDNA) Report from April, 2022. Indeed, using this data, CDC is currently 1,131 homes short of it’s need over the 18-year period. Shortfall exacerbated by the fact that the Plan fails to take account of the full potential of all of the new strategic locations within the District, such as Boxgrove. There is an evidence base that supports the case that Boxgrove has potential to accommodate a strategic level of housing growth, rather than the conclusion that it has limited capacity due to constraints – or the 50 homes proposed by CDC in Plan Policy H3. Strategic level of growth could amount to at least 200 homes, significantly greater than that proposed in Plan Policy H3. Indeed, CDC’s Local Planning Authority (LPA) has an evidence base which does not support the comments made in Paragraph 3.19, Page 38. CDC’s Housing and Economic Land Availability Assessment (HELAA) assessed 9 submitted sites as available, suitable and deliverable for Boxgrove, with a Total Identified Capacity (TIC) for housing of 610 potential plots.

The Housing Distribution Background Paper (May 2024) explains the development of the proposed distribution of housing and the split between strategic and non-strategic provision. The SA report (January 2023, Section 7, sets out the Council’s reasoning for the preferred growth strategy having considered reasonable alternatives, including consideration of Boxgrove.

Object

Representation ID: 4754

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A re-assessment of Boxgrove as a site for strategic level residential development should also take into account Plan Policy S1 regarding the Spatial Development Strategy. We object to the exclusion of Boxgrove from accommodating a strategic level of housing and feel that it should be included in Tier 3, as a settlement to accommodate a strategic development location. However, we do agree with the settlement hierarchy, as outlined in Plan Policy S2, with Boxgrove listed as one of 17 ’Service Villages’.

Whilst the Regulation 19 Local Plan proposes an increase in the parish housing number allocated to Boxgrove, it does not compare as favourably as other settlements for a Strategic Development Location (SDL).

Object

Representation ID: 4758

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Overall, we feel that CDC should be meeting their identified housing need and we disagree with the Council’s justification on meeting a sub-identified need that there is insufficient capacity (due to constraints) within parts of the District.

Furthermore, we feel that the Plan is unsound. It does not adequately meet current housing need. House prices in the Chichester District are 14 times the average earnings for those working within it and there is a need for 200 social and affordable rented houses per annum for the Plan period to 2039.

The justification for not meeting the housing needs in full is set out in the Housing Need (July 2024) and Transport (July 2024) Background Papers.

Object

Representation ID: 4764

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We feel that Plan Policy NE2 on Natural Landscape has a too narrow wording.

Comment noted

Object

Representation ID: 4794

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy NE3 on Landscape Gaps Between Settlements is overly restrictive for all sites outside of the settlement boundaries. In relation to the Plan focus on landscape considerations and the Chichester Landscape Capacity Study from March 2019, we feel that development within the Boxgrove Parish and in particular, the 9 HELAA sites and the 4 settlements outlined in the attached representation, do not involve areas which are so geographically close as to prevent strategic gaps from being safeguarded and thereby secure their individual settlement characteristics.

The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan. The need for any gap will be taken into account in relation to delivering required and identified development.

Object

Representation ID: 4797

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In regards to Plan Policy H2 relating to Strategic Locations/ Allocations 2021 – 2039, we object to the exclusion of Boxgrove Parish from Policy H2. Boxgrove Parish should be listed as a Parish with the potential to accommodate strategic locations for residential development, where Neighbourhood Plans are anticipated to be prepared to identify the site(s) required, alongside the 3 strategic locations currently listed in draft Policy H2 (namely Chichester City, Nutbourne and Hambrook and Loxwood).

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper.

The Housing Distribution Background Paper explains the development of the proposed distribution of housing and the split between strategic and non-strategic provision. The SA report (January 2023, Section 7, sets out the Council’s reasoning for the preferred growth strategy having considered reasonable alternatives, including consideration of Boxgrove.

As set out in the SA and Housing Distribution Background Paper the numbers set for Boxgrove are the most appropriate when taking into account the full range of factors needing to be considered. above.

Object

Representation ID: 4807

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In regards to Policy H3 regarding a Non-Strategic Parish Housing Requirement, we object to the proposed quantum of homes (50 homes) for Boxgrove Parish.

Policy H3 references ‘non-strategic parish housing requirements’, referring to ‘small scale housing sites’. The largest quantum of homes within Policy H3 is 75 additional homes for Wisborough Green. In contrast the lowest quantum of new homes under Policy H2 is 220 new homes at Loxwood. We feel that if Policy H2 defines a strategic level of growth as a minimum of 220 new homes, then Policy H3 should plan for a higher quantum of growth than 75 additional homes.

The Housing Distribution Background Paper (May 2024) explains the development of the proposed distribution of housing and the split between strategic and non-strategic provision. The SA report (January 2023, Section 7, sets out the Council’s reasoning for the preferred growth strategy having considered reasonable alternatives, including consideration of Boxgrove

Object

Representation ID: 4819

Received: 17/03/2023

Respondent: Rydon Homes Limited

Agent: DMH Stallard LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In regards to Policy T1 and Transport Infrastructure, we support efforts to secure ‘the timely delivery of transport infrastructure on the A27 and elsewhere on the network, needed to support new housing, employment and other development identified in this plan’.

We note that it is proposed that all new dwellings (except for West of Chichester SDL and Tangmere SDL) contribute £7,728 (plus indexation) towards the schemes recommended to be provided within the Local Plan period via developer contributions. However, we would like to ask when will this be applicable from (i.e from what date does the indexation commence).

The A27 mitigation contributions set out in paragraphs 8.20 and 8.21 will only become a part of the Statutory Development Plan on the adoption of the new Local Plan. However, National Highways considers that the baseline for assessing the impact of the development identified within the Plan commenced in January 2023 (on the publication of the Local Plan Transport Study).