Chichester Local Plan 2021 - 2039: Proposed Submission

When the revised dwelling requirement is established for Policy H1, the housing figure in Policy H3 for Westbourne should be increased above the currently proposed figure of 30 dwellings.

Westbourne is one of 17 service villages within the plan area with a good range of local services and facilities. As such it is a sustainable location for additional development. This is recognised by allocations in previous Local Plans and more recent housing allocations in the ‘made’ Westbourne Neighbourhood Plan 2021. It is also located close to the western fringe of the district and is therefore less likely to generate traffic movements on the A27 Chichester Bypass.

My clients land at The Shires, Long Copse Lane, Westbourne which is edged red on the plan in the attached response form would make an ideal housing allocation for up to 7 dwellings.

See attached response forms.

Based on the above it is clear that the Policy H1 requirement needs to be reconsidered and increased. This can be achieved if the Local Plan seeks to address infrastructure requirements including the capacity constraints on the A27 as required by paragraph 22 of NPPF.

In setting a revised housing requirement, the District Council must take into account the needs of particular groups (i.e. students and persons in need of affordable homes) and complete the Duty to Cooperate process by preparing a Statement of Common Ground in respect of the unmet needs of the sub-region and then consider how/whether the Local Plan can provide for some of these unmet needs.

The dwelling requirement for the district as set out in Policy H1 of 10,350 dwellings between 2021 and 2039 equates to 575 dwellings per annum (dpa). This does not reflect the current Standard Method requirement of 763 dpa (or 683 dpa when an allowance of 125 dpa is made for the South Downs National Park area).

Furthermore, the housing needs of particular groups are not reflected in the current standard method requirement of 638 dpa. These include the following groups:
• Students – which creates a need for an additional 29 dpa;
• people who require affordable housing- which generates a need of 433 affordable dpa (based on this figure and the thresholds set out in draft Policy H4: Affordable Housing it would be necessary to deliver 1,083 homes per annum to meet affordable housing need in full); and
• the unmet housing needs of neighbouring authorities and/or authorities in the same sub-region, which at best are between 10,141 and 10,620 homes.

When the needs of students are added to the standard method figure the minimum need dwelling requirement would be 666 dpa or 11,988 dwellings over the 18-year plan period 2021-2039.

When the full affordable need of 1,083 dpa is factored in this results in a need for at least 19,494 dwellings over the plan period.

In addition to the above figures, there is also an unmet need for over 10,000 homes in related authorities over the plan period.

Based on the above there is clearly a need for significantly more homes than is suggested by the minimum standard method figure.


Whilst it is noted that there are long-standing highway capacity issues on the A27 Chichester Bypass and more intermittent capacity problems with Wastewater Treatment facilities in the southern part of the district, these could be resolved if the emerging Local Plan made provisions to improve their capacity through proper long-term planning.

This approach is supported by paragraph 22 of the NPPF which confirms that plan-making should respond to long-term infrastructure requirements; and by paragraph 059 Ref ID 61-059 of the Planning Practice Guidance (PPG) which requires local planning authorities and policies that set out infrastructure deficiencies and how these will be addressed.

Existing capacity problems on the A27 are referred to throughout the draft Local Plan and its evidence base. Paragraph 5.2.11 of the SA refers to the southern plan area (i.e. the east-west corridor and Manhood Peninsula) as being highly constrained by capacity on the A27 and to detailed discussions with National Highways and West Sussex County Council (WSCC) over the course of 2019-2022 that led to a resolution that there is capacity for no more than 535 dpa in this area. The background evidence does not, however, make it clear as to how the 535 dpa figure was arrived at or the implications/infrastructure improvements that would be required to accommodate a higher dwelling provision in this part of the plan area.

It is important to note the “Chichester Transport Study - Local Plan Review Transport Assessment” (January 2023) prepared by Stantec is mainly focused on testing a single Local Plan spatial scenario for the period to 2039. Section 5.6 confirms that in addition to testing the 535 dpa in the south of the plan area that a sensitivity test for the delivery of 700 dpa in this part of the plan area was also carried out. Paragraph 5.6.1 confirms that higher levels of Local Plan development would enable higher levels of developer contributions to be raised towards funding the required Local Plan mitigation; and paragraph 5.6.3 comments that generally the proposed Strategic Road Network (SRN) mitigation can accommodate, in the most part, additional increase in development to 700 dpa. This is reiterated in paragraph 5.6.5 where it concludes “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”.

Paragraph 8.5 of the Reg 19 Plan comments that in 2021 National Highways confirmed that the A27 Chichester By-Pass major improvement scheme is included in the Road Investment Strategy Pipeline for the period 2025-30 (RIS3), but at this stage funding is not guaranteed. This situation is not uncommon as are many infrastructure projects which are considered necessary to support the emerging Local Plan. This is demonstrated by Table 3 of the Infrastructure Delivery Plan (January 2023). The fact that the funding has not yet been secured towards certain types of infrastructure, such as healthcare, should not be used as a reason to constrain the level of housing proposed in the emerging Local Plan. This approach also applies to transport infrastructure.

The approach of the Reg 19 Plan to impose limits on the amount of development over the Plan period because of existing infrastructure capacity issues is inconsistent with the objectives of national policy and could undermine the prospects of securing the funding necessary to improve infrastructure capacity. The approach of the emerging plan is therefore negatively worded as it has the effect of constraining the level of housing below the minimum level needed and does not accord with the PPG or the objectives of national policy. A better, and more positive approach would be to plan for the necessary infrastructure, which in turn will maximise the prospects of securing the required infrastructure instead of deferring it.