Chichester Local Plan 2021 - 2039: Proposed Submission

The timescale of the plan submission should be amended to allow for the confirmation of national planning policy. In the meantime, to guard against speculative development, there should be a moratorium on building in the district.

The NPPF is currently under review and may result in a shift in Government Policy on development - particularly on housing targets. We feel that the publication of the Chichester Local Plan pre-empts the outcome of the consultation and potential change in national planning policy.

This is a comment only

There has been no further public consultation on the preferred approach since 2018/19, four years have passed since this time. The issues that were raised during that consultation are still relevant today, and have not been addressed within the new proposed Plan. The reduction in housing numbers in the revised plan does not adequately reflect the challenges and constraints of the infrastructure issues, particularly waste water treatment and the A27. The impact on sensitive landscapes has not been properly addressed, with 1,600 houses proposed on the Chichester Harbour AONB boundary without active engagement with Chichester Harbour Conservancy over the impact (particularly the allocated site A11 at Highgrove Farm, Bosham.

Chichester Harbour provides a significant economic benefit to the district's economy. Although dated now (2009, UE Associates) the Valuing Chichester Harbour study found that there were 455 businesses in the Harbour, and that the contribution to the local economy was £2.78 billion.
This cumulative figure is made up of individual valuation information from maritime businesses (£524M), residential property (£2,151M), tourism (£44M), land values (£52M) and recreation (£1.2M). This document is available on Chichester District Council's website: https://www.chichester.gov.uk/media/7890/Valuing-Chichester-Harbour-2009---Part--1/pdf/Valuing_chichester_harbour_part_1.pdf

Reduction in the housing allocation, particularly the distribution along the boundary of the Chichester Harbour AONB.

The over-reliance of development in the east-west corridor risks delivering unsustainable levels of housing on unwilling communities - particularly between Chichester and Emsworth to the west of the city. The proposed delivery of 3,225 houses in this area (1,600 west of Chichester, 1,050 Southbourne, 245 Bosham, 300 Chidham & Hambrook, 30 Fishbourne) cannot be reconciled with the objectives of conserving local distinctiveness, character and cohesion of settlements. The infrastructure to support this level of development is simply not in place, and is unlikely to be through the Plan duration (particularly waste water treatment, roads, doctors, schools). The proposed levels of development are disproportionate to the size of the existing settlements, and therefore will be default alter their character immeasurably.

We absolutely support this aspiration; however by default the Plan fails to deliver this in any meaningful way. The levels of housing development proposed are incompatible with the aspirations outlined. The south of the district occupies low-lying coastal plain, which is highly vulnerable to coastal change and sea level rise. Ground water levels are high, leading to frequent flooding. Conversely, the region also suffers from water scarcity issues due to climate change. As a matter of course, most new developments in the area are highly car-reliant, as the public transport and cycling infrastructure is not able to provide a viable alternative.

We support these ambitions. However in reality it is unlikely that the proposed plan will be able to deliver these aspirations. The volume of housing proposed between Chichester and Emsworth (3,225), especially when combined with Havant Borough Council's strategic site at Southleigh (2,100 homes) will lead to an unprecedented level of development pressure on the AONB, SSSI/SPA designated site at Chichester Harbour. Inevitably the repercussions for waste water treatment (already at full capacity and storm discharging regularly) and additional recreational disturbance will further compound the challenges affecting the protected site, meaning that it is unable to recover from the current "Unfavourable Declining" condition assessment.

We support the reference to the need for waste water service providers to work with regulators to ensure adequate provision for the delivery of the plan. However we fear that in reality the required infrastructure will not be deliverable in the timescale of the Plan delivery which will lead to the continued discharging of untreated effluent into Chichester Harbour and other water bodies, including the Lavant, which flows into the Harbour. This will lead to the continued ecological decline of the harbour and work directly against the ambitions to restore it to favourable condition.

A significant reduction in the housing allocation in the east-west corridor is required.

The Plan promotes an over-reliance on developing the east-west corridor, with unsustainable levels of development between Chichester and Havant. Combined with the Havant Borough strategic site at Southleigh (2,100 homes) this leads to a delivery of 5,300 new houses in the narrow corridor between Chichester Harbour AONB/SSSI and the South Downs National Park. The ecological and landscape implications of this over-development are huge; both for biodiversity and for local communities. Just some of the impacts include inadequate waste water infrastructure; lack of transport infrastructure; inadequate community facilities including schools and doctors services. Potential ramnifications are increased congestion, light and noise pollution; waste water discharges; recreational disturbance, to name just a few.
The additional burden of this increased population will further compound and render irreversible the ecological decline of Chichester Harbour SSSI.
As a general comment, the plan in this area is overly reliant on the delivery of green-field sites, raising important concerns over sustainability; agricultural production, food security, groundwater and surface water drainage and flooding.

We welcome the ambitions of this statement. However we note that it does seem directly at odds with the delivery of 3,225 houses on greenfield sites in the east-west corridor.

We welcome the inclusion of this paragraph. However it is important to recognise that it is not only development control within the AONB itself but the landscape context and over-development around the boundary of the AONB that cumulatively leads to threats to the integrity of the AONB landscape, setting and ecological condition. The development of 3,225 additional properties in close proximity to the AONB will have indirect impacts in terms of water quality and recreational pressure particularly.