Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE4 should be revised to the following text:

Development proposals will only be permitted where it would not lead to a significant adverse effect upon the ecological value, function and connectivity of the strategic wildlife corridors.

Development proposals within strategic wildlife corridors will only be granted where it can be demonstrated that:

1. The development will not have a significant adverse impact on the function of the wildlife corridor and protects and enhances its features and habitats.
2. The proposal will not undermine the connectivity and ecological value of the corridor.

Development proposals outside, but in close proximity to the strategic wildlife corridor will be acceptable where it can be demonstrated that:

a) The development will not have a significant adverse impact on the function of the wildlife
corridor; and
b) The proposal will not undermine the connectivity and ecological value of the corridor.

All proposals for new development (with the exception of householder applications) within or in close proximity to wildlife corridors should take opportunities available in order to extend or enhance those corridors.’

d) Strategic Wildlife Corridors

2.36 Draft Policy NE4 proposes the introduction of Strategic Wildlife Corridors (SWC), with consideration of the locations and rationale for these as set out in the Strategic Wildlife Corridors Local Plan Review Background Paper (December 2018). The 4no. identified corridors seek to provide ecological connectivity between Chichester Harbour SPA or Pagham Harbour SPA and the South Downs National Park.

2.37 These Representations are accompanied by a ‘Review of Policy NE4’ prepared by Aspect Ecology (Appendix A), which reviews the proposed Wildlife Corridors, with specific reference to the West of Chichester to Fishbourne Strategic Wildlife Corridor (SWC4) that is partly located within Gleeson’s Site at Land West of Clay Lane, Fishbourne.

2.38 As detailed in the accompanying Ecology Technical Note prepared by Aspect Ecology:

• The SWCs appear to avoid areas of intensively farmed arable land, with areas of built development and urban areas preferentially incorporated over arable land. Thereby acknowledging that residential areas often retain functional habitat for wildlife, particularly within green infrastructure, and can readily meet the requirements of the Strategic Wildlife Corridors in terms of ensuring ecological connectivity is maintained for wildlife through the landscape;
• Residential development can contribute positively to the function of the corridors particularly where key habitats are retained and green infrastructure is included;
• Subject to a sensitive ecologically led masterplan, development can be accommodated whilst fully maintaining the functional elements of the corridor. Appropriate development could bring forward considerable benefits to biodiversity through securement of long-term favourable management; and
• There exists an opportunity to extend SWC4 to the east of the A27 to strengthen the ecological network.

2.39 Further, the Ecology Technical Note proposes changes to the wording of Policy NE4, which we consider necessary for soundness - specifically the removal of the requirement to demonstrate there are no “sequentially preferable” sites available outside a SWC and that any proposed development would not have a significant adverse impact on the “integrity” and function of a corridor as a whole. This is due to:

• Sensitive development can positively contribute to the objectives of SWCs;
• The policy as worded conflicts with the requirements of Paragraph 180 of the NPPF noting that avoidance measures (including consideration of alternative sites) are not required if significant harm to biodiversity is avoided; and
• An “integrity” test relates to paragraph 182 of the NPPF and the assessment of effects on SPAs/SACs/Ramsar sites in the context of an Appropriate Assessment, it is not appropriate for SWCs, which are a lower level of local designation. The wording of the policy should reflect the protection afforded to be proportionate to their designation status.

2.40 It is our view the sequential test should only be applied in circumstances where the NPPF advocates for this, i.e. cases relating to Flood Risk, Town Centre uses and where there is significant harm to biodiversity resulting from development which cannot be avoided, adequately mitigated or compensated for (which as reflected above is not the case for any development in the SWC).

2.41 Policy NE4 as drafted is considered not to be “sound” on the basis it is not positively prepared, not justified, not consistent with national policy and would not lead to an effective strategy for growth (i.e. supressing development on potentially suitable sites). Policy NE4 should be amended to more accurately reflect the objectives and role of the SWC, with our proposed wording:

Development proposals will only be permitted where it would not lead to a significant adverse effect upon the ecological value, function and connectivity of the strategic wildlife corridors.

Development proposals within strategic wildlife corridors will only be granted where it can be demonstrated that:

1. The development will not have a significant adverse impact on the function of the wildlife corridor and protects and enhances its features and habitats.
2. The proposal will not undermine the connectivity and ecological value of the corridor.

Development proposals outside, but in close proximity to the strategic wildlife corridor will be acceptable where it can be demonstrated that:

a) The development will not have a significant adverse impact on the function of the wildlife
corridor; and
b) The proposal will not undermine the connectivity and ecological value of the corridor.

All proposals for new development (with the exception of householder applications) within or in close proximity to wildlife corridors should take opportunities available in order to extend or enhance those corridors.’

2.42 In addition, the supporting text at paragraph 4.18 should be amended to refer to the function of the corridor not the integrity as set out above in relation to NPPF paragraph 182. The revised text should read:

4.18 The Council will apply an additional layer of planning restraint to the countryside protection policies within these strategic wildlife corridors to ensure that connectivity between the South Downs National Park and the Chichester Harbour AONB and Padgham Harbour is maintain in the long term. Within the corridors it will be necessary to demonstrate that no land outside of the corridor is available for development and the development will not have an If a significant adverse impact on the function of the corridor resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then it will not be permitted.

We proposed the following changes:

1) Increase the Policy H1 housing figure to at least 712 dpa (12,816 dwellings over the plan period) to meet the standard method figure in full; to help meet unmet needs arsing within the South Downs National Park; and to provide a 5% delivery buffer:
2) Increase the Policy H1 East-West Corridor sub-area housing provision figure from 8,717 dwellings to 11,174 dwellings between 2021 to 2039.
3) Update the Policy H1 components of housing supply figures, in particular the ‘Category b Known commitments’ following a critical review of the deliverability of the respective supply sites.
4) Re-consideration locations previously identified in the Preferred Approaches consultation as sustainable / suitable locations for growth, such as Fishbourne.

c) Meeting Housing Needs

i) The Housing Requirement

2.22 Para 5.2 of the draft Local Plan identifies a constrained supply figure of 575dpa is proposed, below the identified housing needs for the District which is calculated at 638dpa (through the Standard Method). This equates to a shortfall of 1,134 dwellings against identified housing needs across the Plan period of 2021 – 2039 or circa. 10% of the identified housing needs.

2.23 Moreover, the draft Plan no longer seeks to provide an additional allowance for accommodating unmet need arising from the South Downs National Park. The draft Plan notes that this is due to constraints arising from transport capacity, in particular, the operational capacity of the A27 Chichester by-pass which forms part of the Strategic Road Network governed by National Highways.

2.24 However, we consider this position is not positively prepared and is unjustified, and therefore results in a Plan which is not “sound”.

2.25 This is because on a review of the Local Plan Transport Study (January 2023) (LPTS) there appear to be significant matters which have not been considered by the Council which would allow identified housing needs to be achieved in full. This includes:

• The LPTS and draft Local Plan makes no allowance for the RIS 3 funding review, which is due to be concluded in 2023/24. The A27 has previously been identified as a location for government investment (circa. £100m), with the funding only withdrawn as it was not possible to get consensus between local authorities. However, it is reasonable to assume that an award of funds is likely through RIS 3. An award of fund through RIS3 would significantly increase network capacity on the A27, which in turn would enable greater levels of growth to be realised – it is noted that the LPTS sensitivity testing demonstrates an additional 165dpa can be achieved with the delivery of the full mitigation package.;

• The modelling underpinning the LPTS may overestimate the amount of traffic that is likely to be generated by the planned growth strategy. A blanket trip rate may not be reflective of the nature and location of identified developments, and no allowance has been made for the internalisation of trips within strategic sites, and the allowance made for sustainable travel (5%) does not correspond with WSCC Travel Plan targets (10%);

• The baseline traffic flows informing the modelling has a 2014 base, with further validation undertaken in 2018. Changes to traffic flows as a result of behavioural change since the Covid-19 pandemic will therefore not be reflected in the assessment;

• In the period since the modelling informing the LPTS has been undertaken, future traffic growth has been reforecast by the Department for Transport and subsequently released in December 2022. The forecast growth is considerably lower than that used to inform the LPTS, and thus the assessment overestimates future year base line flows;

• No additional modelling of a 700 dpa strategy with the reduced mitigation package has been undertaken. It has not been demonstrated that the proposed package of measures cannot accommodate an uplift in dpa;

• The mitigation strategy appears to goes beyond mitigation of the development impacts and result in an improvement of conditions beyond the baseline flows. This would suggest that there is headroom in the strategy to accommodate an uplift in dpa, even without improvements at Stockbridge;

• There is a significant difference in the costing outputs of the mitigation strategy prepared by Stantec, as authors of the LTPS, and the CDC-WSCC revisions. It is not unreasonable to assume that the Stantec costings are accurate, given its experience of such infrastructure and that the exercise was informed by National Highways, who govern the A27 as part of the Strategic Road Network. Further consideration should be given as to whether the uplifted costs presented by CDC-WSCC are accurate.

2.26 We therefore consider that the CDC should be looking to meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet need from South Downs National Park, which was identified as circa. 40dpa in the Preferred Approaches consultation (December 2018). In addition, an appropriate buffer (i.e. 5%) should also be applied to ensure there is a realistic prospect of meeting housing needs.

2.27 If CDC was to adopt this approach, it would result in an increased requirement of 712 dpa, or 12,816 dwellings over the course of the Plan period. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes would need to be identified and allocated through the Plan to address this uplift.

2.28 In meeting this additional need, re-consideration of locations previously identified in the Preferred Approaches consultation as sustainable / suitable locations for growth, such as Fishbourne, would clearly be required.

ii) Components of Supply

2.29 Policy H1 (Meeting Housing Needs) identifies that the total supply across the Plan Period (of 10,359 dwellings) is comprised of:

• Completions 2021/22 – 712 dwellings;
• Known commitments:
o Outstanding 2015 Local Plan and Site Allocations DPD 2014 – 2029 allocations without permission – 2,210 dwellings;
o Outstanding ‘made’ Neighbourhood Plan allocations without planning permission – 100 dwellings; and
o Planning permission as of 01 January 2023 – 3,364 dwellings.
• New Strategic Locations / Broad Locations for Development and Allocations without planning permission – 3,056 dwellings;
• Non-Strategic Parish Housing Requirements without planning permission – 260 dwellings; and
• Windfall (small site allowance) – 657 dwellings.

2.30 A significant proportion of the above ‘known commitments’ (circa. 21%) comprise outstanding allocation from the 2015 Local Plan and 2014 Site Allocations DPD. These allocations, that do not benefit from planning permission, have simply been ‘carried forward’ from previous Plan-making exercises. Given the time which has elapsed since these allocations were previously considered and adopted, and the lack of progress being made in delivering homes at these allocations, the Council should satisfy itself that these allocated sites remain suitable and deliverable locations for re-allocation in the draft Plan. It is considered that the approach of carrying these allocations forward and re—allocating them within the draft Local Plan without evidence to confirm they remain deliverable or developable renders these allocations as unjustified. Clearly, if there is insufficient evidence to confirm these sites are deliverable or developable, then this brings into question whether re-allocating these sites in the draft Plan is an effective strategy for addressing growth requirements.

2.31 Further, of the above components of supply in Policy H2 (Strategic Locations / Allocations) 2,150 dwellings (circa. 21%) are attributed to broad locations (in the case of 1,050 dwellings in Southbourne) or neighbourhood planning areas (for the locations of Chichester City, Nutbourne and Hambrook, Loxwood, Boxgrove, Fishbourne, Kirdford, North Mundham, Plaistow and Ifold, Westbourne, and Wisborough Green) where specific sites will be allocated through Neighbourhood Plans or a subsequent Development Plan Document.

2.32 As indicated by the Housing Trajectory at Appendix E of the draft Local Plan there is a clear need for new allocation sites to come forward quickly, especially as existing sites under construction are scheduled to (in the main) conclude within the next 3 – 5 years.

2.33 We consider there is a significant risk from the current strategy which effectively postpones identifying site specific allocations for over 1/5 of the current housing requirements until further Plan-making exercises are completed. As currently drafted, we consider the strategy is not positively prepared, nor would it be effective in addressing housing needs over the Plan period.

2.34 We consider this could be rectified through the identification and allocation (through the emerging Plan itself) of additional suitable sites, such as Gleeson’s site in Fishbourne as detailed in Section 3.

Recommended Change
2.35 In view of the above, we proposed the following changes:

1) Increase the Policy H1 housing figure to at least 712 dpa (12,816 dwellings over the plan period) to meet the standard method figure in full; to help meet unmet needs arsing within the South Downs National Park; and to provide a 5% delivery buffer:

Housing Figure Element Dwellings Per Annum Dwellings between 2021 and 2039
Standard Method 638 11,484
South Downs National Park Unmet needs Allowance 40 720
5% Delivery Buffer 34 612
Total Housing Figure 712 12,816

2) Increase the Policy H1 East-West Corridor sub-area housing provision figure from 8,717 dwellings to 11,174 dwellings between 2021 to 2039.
3) Update the Policy H1 components of housing supply figures, in particular the ‘Category b Known commitments’ following a critical review of the deliverability of the respective supply sites.

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.

Fishbourne should be recognised as a 'more sustainable' location where additional strategic-scale growth can and should occur. The housing requirement for Fishbourne should revert back to the amount set out in the Preferred Approach version of the Local Plan which was for 250 homes.

2.11 Chapter 3 of the draft Local Plan defines how housing and other needs will be met spatially across the District, in accordance with a defined settlement hierarchy.

2.12 Paragraphs 3.5 through 3.28 of the Draft Local Plan summarise the rationale for the proposed distribution of growth, including noting:

• That growth is required in both urban and rural areas to meeting needs;
• The focus remains on Chichester city as a main sub-regional centre and the most sustainable location;
• Outside of Chichester, development will be focused on ‘settlement hubs’ within the east-west corridor at Tangmere and Southbourne;
• Outside of these locations land for new development will be identified and allocated through the Local Plan or a neighbourhood plan at Service Villages where there are suitable locations to do so; and
• The Local Plan aims to continue to protect the countryside.

2.13 Draft Policy S1 (Spatial Development Strategy) broadly reflects the above, and states that “new residential and employment development is [to be] distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements”. The corresponding table identifies a range of ‘Strategic Development Locations’ which are considered to be the ‘more sustainable settlements’ including the service villages of Bosham, Hambrook / Nutbourne (combined) and Loxwood.

2.14 Draft Policy S2 (Settlement Hierarchy) expands this list to include a wider range of settlements where development will be delivered through site allocations as well as windfall development in accordance with other policies in the draft Plan.

2.15 Whilst we have no objection to the principle of distributing the majority of growth to the most sustainable location, subject to consideration of constraints, it is our view the Council has not sufficiently justified the rationale behind its settlement hierarchy.

2.16 This is because a key settlement, Fishbourne, has been overlooked in the settlement hierarchies set out in draft Policies S1 and S2 without good reason. Fishbourne, has not been identified as a more sustainable settlement and ‘Strategic Development Location’ in the table at draft Policy S1, and has instead only been identified in draft Policy S2 as a ‘Service Village’, and a location for the non-strategic provision of only 30 homes. This is despite Fishbourne being a highly sustainable location with suitable and deliverable locations for growth (including Gleeson’s site as detailed in Section 3).

2.17 No evidence is provided which considers the sustainability of Service Centres that provides justification for Hambrook / Nutbourne, Loxwood and Bosham being elevated over Fishbourne.

2.18 From our own review, it is clear there is no rationale for this, as shown below:

Current population Sustainable transport options Existing services / facilities Draft Local Plan proposals
Fishbourne 2,666 Train Station and bus services Primary School
Medical Practice
Public Houses
Community Hall
Supermarket (Tesco Extra)
Roman Palace (inc. coffee shop) 30 homes
Hambrook / Nutbourne Hambrook: 1,908
Nutborne: 1,962

Combined total: 3,870 Train Station (Nutbourne) and bus services Post office
Public House 300 homes
Loxwood 1,026 Bus services Primary School
Medical Practice
Post Office
Community Hall 220 homes
Bosham 1,578 Train Station and bus services Primary School
Medical Practice
Post office
Co-op shop
Churches
Public Houses 245 homes


2.19 We consider that Fishbourne should instead be recognised as a ‘more sustainable’ location where additional strategic-scale growth can and should occur. It has a commensurate number of services and facilities compared to other Service Villages. The proximity to Chichester compared to the other Service Centres and the multitude of employment opportunities and facilities there is also a unique strength of Fishbourne. It also benefits from a nearby Tesco Extra.

2.20 This would be consistent with the Regulation 18 Preferred Approach (December 2018) consultation which identified (through the previous version of draft Policy S1 – at that stage identified as Policy S3 Development Strategy) Fishbourne as a “larger and more sustainable settlement”, alongside Bosham, Hambrook / Nutbourne and Hunston, with an allocation of a “minimum of 250 dwellings”. Loxwood was not recognised as a more sustainable settlement at that time, albeit was still identified to accommodate 125 homes.

2.21 No information has been provided to justify this change in approach between the Regulation 18 and Regulation 19 consultation. We therefore consider the current approach to the Spatial Strategy is not justified and consider draft Policy S1 not “sound”.

The Chichester Transport Study has concluded the southern planning area can generally accommodate 700 dwellings per annum, with proposed mitigation. The SA conclusion that there is capacity for no more than 535dpa is therefore fundamentally flawed.

The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited, as this too has been infected by the factually incorrect SA.

e) Sustainability Appraisal

2.43 By way of context to these representations, we note that the Chichester Transport Study, dated January 2023, concludes at paragraphs 5.6.5 and 11.2.3:

“5.6.5 It is concluded that in the main, the 700 dpa (southern plan area) demands can generally be accommodated by the mitigation proposed for the 535 dpa core test although at the Portfield roundabout and Oving junction, capacity issues get worse with the 700 dpa demands, with additional mitigation being required. As no schemes have been designed to date, it would be advisable to retain some costs against for future works against Portfield Roundabout as a minimum.”

“11.2.3 A sensitivity test with 700 dpa has been undertaken. It is concluded that in the main, the 700 dpa demands can generally be accommodated by the mitigation proposed for the 535 dpa core test, although at the Portfield roundabout and Oving junction, capacity issues get worse with the 700 dpa demands and these junctions may need to consider further mitigation. As no schemes have been designed to date, it would be advisable to retain some cost against for future works against Portfield Roundabout as a minimum. It is unlikely there would be significant capacity in the network beyond 700 dpa, considering full mitigation package.”

2.44 Although the Transport Study is dated January 2023, it is noted that the report’s Document Control Sheet (page ii) confirms it was first issued back in April 2022, and has since been the subject of revisions prior to finalisation.

2.45 The Transport Study conclusion that 535 dwellings per annum (dpa) was not an absolute ‘cap’ to housing development within the southern planning area was therefore well known to the Council during the time that the SA was being prepared to inform draft CLP decision-making process.

2.46 In view of the above, we are fundamentally concerned that the basis of the reasonable alternatives tested have been infected by a fundamentally flawed starting point conclusion that there is capacity for no more than 535 dpa within the southern planning area:

“The southern plan area (i.e. the east west corridor and Manhood Peninsula) is highly constrained by capacity on the A27. Detailed discussions with National Highways and WSCC, over the course of 2019-2022, have led to a resolution that there is capacity for no more than 535 dpa in this area” (paragraph 5.2.11, first bullet).

2.47 The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited, as this too has been infected by the factually incorrect SA.

2.11 Chapter 3 of the draft Local Plan defines how housing and other needs will be met spatially across the District, in accordance with a defined settlement hierarchy.

2.12 Paragraphs 3.5 through 3.28 of the Draft Local Plan summarise the rationale for the proposed distribution of growth, including noting:

• That growth is required in both urban and rural areas to meeting needs;
• The focus remains on Chichester city as a main sub-regional centre and the most sustainable location;
• Outside of Chichester, development will be focused on ‘settlement hubs’ within the east-west corridor at Tangmere and Southbourne;
• Outside of these locations land for new development will be identified and allocated through the Local Plan or a neighbourhood plan at Service Villages where there are suitable locations to do so; and
• The Local Plan aims to continue to protect the countryside.

2.13 Draft Policy S1 (Spatial Development Strategy) broadly reflects the above, and states that “new residential and employment development is [to be] distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements”. The corresponding table identifies a range of ‘Strategic Development Locations’ which are considered to be the ‘more sustainable settlements’ including the service villages of Bosham, Hambrook / Nutbourne (combined) and Loxwood.

2.14 Draft Policy S2 (Settlement Hierarchy) expands this list to include a wider range of settlements where development will be delivered through site allocations as well as windfall development in accordance with other policies in the draft Plan.

2.15 Whilst we have no objection to the principle of distributing the majority of growth to the most sustainable location, subject to consideration of constraints, it is our view the Council has not sufficiently justified the rationale behind its settlement hierarchy.

2.16 This is because a key settlement, Fishbourne, has been overlooked in the settlement hierarchies set out in draft Policies S1 and S2 without good reason. Fishbourne, has not been identified as a more sustainable settlement and ‘Strategic Development Location’ in the table at draft Policy S1, and has instead only been identified in draft Policy S2 as a ‘Service Village’, and a location for the non-strategic provision of only 30 homes. This is despite Fishbourne being a highly sustainable location with suitable and deliverable locations for growth (including Gleeson’s site as detailed in Section 3).

2.17 No evidence is provided which considers the sustainability of Service Centres that provides justification for Hambrook / Nutbourne, Loxwood and Bosham being elevated over Fishbourne.

2.18 From our own review, it is clear there is no rationale for this, as shown below:

Current population Sustainable transport options Existing services / facilities Draft Local Plan proposals
Fishbourne 2,666 Train Station and bus services Primary School
Medical Practice
Public Houses
Community Hall
Supermarket (Tesco Extra)
Roman Palace (inc. coffee shop) 30 homes
Hambrook / Nutbourne Hambrook: 1,908
Nutborne: 1,962

Combined total: 3,870 Train Station (Nutbourne) and bus services Post office
Public House 300 homes
Loxwood 1,026 Bus services Primary School
Medical Practice
Post Office
Community Hall 220 homes
Bosham 1,578 Train Station and bus services Primary School
Medical Practice
Post office
Co-op shop
Churches
Public Houses 245 homes


2.19 We consider that Fishbourne should instead be recognised as a ‘more sustainable’ location where additional strategic-scale growth can and should occur. It has a commensurate number of services and facilities compared to other Service Villages. The proximity to Chichester compared to the other Service Centres and the multitude of employment opportunities and facilities there is also a unique strength of Fishbourne. It also benefits from a nearby Tesco Extra.

2.20 This would be consistent with the Regulation 18 Preferred Approach (December 2018) consultation which identified (through the previous version of draft Policy S1 – at that stage identified as Policy S3 Development Strategy) Fishbourne as a “larger and more sustainable settlement”, alongside Bosham, Hambrook / Nutbourne and Hunston, with an allocation of a “minimum of 250 dwellings”. Loxwood was not recognised as a more sustainable settlement at that time, albeit was still identified to accommodate 125 homes.

2.21 No information has been provided to justify this change in approach between the Regulation 18 and Regulation 19 consultation. We therefore consider the current approach to the Spatial Strategy is not justified and consider draft Policy S1 not “sound”.