Chichester Local Plan 2021 - 2039: Proposed Submission

Berkeley support the principle of the strategic policies and, in particular, their purpose in setting out the development needs of the district and the spatial strategy. Berkeley have a number of comments on these policies, which are set out below.

Policy S2 demonstrates that Chichester City is the largest and most sustainable settlement in the district and is the only settlement in the Sub-Regional Centre tier. Berkeley therefore supports the approach that the majority of growth should be focussed around Chichester City, given its capacity for development.

Berkeley supports the purpose of the settlement hierarchy, to guide the location of development to the most sustainable locations. The majority of new housing should be located at settlements that sit at the top of the settlement hierarchy, such as Chichester City, given they provide the most sustainable locations for growth and thus enable easy access to jobs and facilities without the need to travel long distances.

Chichester City is the largest settlement in the district and Berkeley therefore supports its placement in its own category at the top of the settlement hierarchy.

Berkeley believe that additional housing sites should be allocated at Chichester City to better reflect the Spatial Strategy and more fully meet the identified housing need.

Berkeley supports focussing the majority of growth at the sub-regional centre of Chichester City, with the majority of strategic allocations (both extant and new) proposed within or adjacent to the city. Policy S1 refers to a total of six allocations around Chichester City, which could deliver 4,080 homes.

Berkeley objects to the level of growth proposed at Chichester City as it fails to adequately reflect the suitability and capacity of the city to accommodate growth.

Whilst it has been acknowledged that Chichester City is the most appropriate location for development, Berkeley believes that there are additional sites at the city that can come forward in the plan period as they are not subject to the constraints which have been identified as restricting the ability of the District to meet its housing need in full. Berkeley therefore objects to this policy.

Please see comment on Policy H1.

Berkeley considers that the local plan must make provision to meet, as a minimum, the housing needs of the district in full to support economic growth, promote sustainable patterns of travel, reduce housing unaffordability and meet the housing needs of all sectors of the community, particularly first time buyers, the elderly and those who are unable to secure a home on the open market.

To assist in providing the necessary additional level of growth in the district, there is a need to recognise the suitability of additional sites on the edge of Chichester City, through the allocation of additional housing sites such as land at Lawrence Farm in Fishbourne Parish.

Paragraph 11b of the National Planning Policy Framework indicates that policies should, as a minimum, provide for objectively assessed needs for housing, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

Paragraph 60 of the NPPF sets out that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

To establish the minimum number of homes needed, paragraph 61 sets out that strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

Paragraph 66 goes on to set out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period.

Berkeley supports the identified housing need of 11,484 homes over the plan period, which equates to 638 per annum, calculated using the Standard Method and referenced in paragraph 5.1 of the Local Plan. However, it should be noted that this does not include any allowance for assisting with unmet need from the part of the South Downs National Park within Chichester District.

Policy H1 sets a housing requirement of 10,350 homes during the plan period, equating to 575 dwellings per annum.

As such, a shortfall of 1,134 dwellings exists against the calculated housing need. The plan seeks to justify this shortfall at paragraph 5.2 as a result of perceived constraints across the district, including the capacity of the A27.

The draft plan and evidence base provides limited justification for this shortfall. Berkeley therefore considers that, having regard to paragraph 11(b) of the NPPF, the draft plan fails to provide a strong reason for restricting the overall scale, type or distribution of development based on the application of policies in the Framework that protect areas or assets of particular importance.

Chichester Council have produced a Duty to Cooperate Statement of Compliance as part of their Local Plan evidence base. Whilst it has been demonstrated that the Council have attempted to establish if any neighbouring authorities can accommodate the Council’s unmet need, no local authorities have indicated that they are able to accommodate some of the unmet need, as referred to in paragraph 5.21.

As a result, the responsibility falls back to Chichester District Council to fulfil the unmet need within its own boundaries.

Fundamental to the soundness of the local plan and the future environmental, social and economic sustainability of the district is the need for the local plan to plan positively to meet the housing needs of the district in full.

Berkeley does not support this lower housing requirement than the identified need on the basis that the Local Plan has failed to identify sufficient grounds upon which to diverge from the District’s housing need. Additionally, Berkeley believes there is greater capacity for suitable housing growth at Chichester City than has been identified in the draft plan.

The housing requirement of 10,350 is capacity led and has been reached given constraints such as the capacity of the A27. Additional capacity for development can be identified in the HELAA that is well located in relation to Chichester City which can assist the Council in delivering a housing supply closer to the identified need of the District and continue to accord with the spatial strategy of Policy S1.

It is important to note that the Inspectors Report for the Worthing Local Plan (October 2022) emphasises meeting housing needs as the ‘most important and pressing of all strategic issues’. Chichester Council should therefore utilise as much available capacity as possible to contribute to meeting their housing need.

Berkeley does not consider that the evidence provided to suggest this additional capacity cannot be brought forward demonstrates strong reasons why the overall scale of growth in the district should be restricted.

The Sustainability Appraisal and supporting evidence provide insufficient evidence to demonstrate that strong reasons exist for restricting the level of housing provision. Additionally, it is not demonstrated that the adverse impacts of delivering the housing need in full would significantly and demonstrably outweigh the benefits.

The Local Plan needs to provide a greater level of housing to Fishbourne Parish, given its proximity to Chichester City and available capacity, in order to contribute to meeting the housing need of the District.

Fishbourne is an area that is well located to Chichester City and should therefore be prioritised as a location for development. The emerging Local Plan, at Policy H3, indicates a housing figure of 30 dwellings to be allocated through the Fishbourne Neighbourhood Plan. Five sites in the parish have been assessed in the HELAA and subsequently discounted, including Lawrence Farm. Given its proximity adjacent to the southern edge of Chichester City and its highly sustainable location, Berkeley believes the site should be allocated in the Local Plan or the Parish housing allocation be increased to enable a review of the Neighbourhood Plan to allocate sites to meet the local housing need more fully.

This representation has been submitted by Berkeley Strategic (“Berkeley”) in response to the current consultation on the Regulation 19 Chichester Local Plan.

Berkeley control approximately 3.67 hectares acres of land to the south of Chichester. The site is located adjacent to Fishbourne Roundabout and is referred to in the Housing and Economic Land Availability Assessment as HFB0027. The site was previously included in Policy AL6 as part of a wider employment development parcel.

Berkeley support the preparation of the Local Plan and welcomes the opportunity to comment on the plan at this early stage of its preparation.

Berkeley supports the Council’s methodology of allocating housing sites to meet the housing and economic development needs of Chichester District, based primarily on their suitability, availability and achievability.

Berkeley supports the carry forward of existing local plan strategic site allocations. The delivery of these sites provides a critical component of the housing supply in the early years of the plan period and should be regarded as being a priority.

A greater level of housing needs to be included around Chichester City, given the additional capacity.

Policy H2 the local plan suggests a further 1,125 homes could be delivered through the allocation of three new sites around Chichester City.

Inclusive of the three proposed site allocations, the total proposed level of housing around Chichester City stands at 4,080 dwellings. Given the length of the plan period, and the strategic importance of Chichester City, as outlined above, Berkeley considers there is greater capacity for development surrounding Chichester City, which can contribute towards the current shortfall, such as land at Lawrence Farm.

Given that Lawrence Farm was previously included in a proposed allocation for development, it is considered that land at Lawrence Farm can assist in the Council’s ambitions of augmenting the capacity of the A27, through facilitating improvements to Fishbourne Roundabout and can provide an addition to the delivery of housing in Fishbourne Parish. It should therefore be included in the Local Plan.

The Berkeley Group is the sole owner of Lawrence Farm, which is located directly adjacent to the A27 Fishbourne Roundabout to the south of Chichester.

The site is located in close proximity to the edge Chichester City, which as discussed above, is the most sustainable settlement in the district. The site therefore represents a suitable location for development, in accordance with the spatial strategy.

The site has previously been found suitable, was included as part of site allocation AL6 in the Reg 18 draft plan and would assist in the delivery of the Stockbridge Link Road. However, in isolation the site has been discounted for the sole reason that the site in isolation is not considered suitable due to significant flood risk as a result of climate change.

This is the only reasoning given for the site being discounted and should therefore be considered suitable in all other respects. As such, any part of the site that is not within the perceived area of flood risk as a result of climate change is unconstrained and therefore suitable for development.

An area to the north of the site is unconstrained by flooding as a result of climate change and can accommodate circa 25 dwellings. This could provide a small contribution towards the shortfall of housing in the District and should be included as an allocation to Fishbourne Parish under Policy H3, which should increased by 25 houses to reflect the suitability and capacity of the site.

The site is owned by a single landowner and is therefore available.

Development upon the unconstrained part of the site would not prejudice the delivery of the northern most section of the Stockbridge Relief Road, connecting the A27/A259 Fishbourne Roundabout and the A286 Birdham Road in the future. Any small scale development on the site would not prejudice the land for the relief road.

Additionally, paragraph 5.2.21 suggests proposals to safeguard land for upgrades to the Fishbourne roundabout. Land at Lawrence Farm is directly adjacent to the Fishbourne roundabout and can therefore be utilised effectively to facilitate future junction improvements.