Chichester Local Plan 2021 - 2039: Proposed Submission

A reduction in the housing allocation numbers to a much more sustainable level

The current waste water treatment system is inadequate and unable to deal with combined household and surface water discharges at the present time. This is only going to be exacerbated by the proposed level of development, particularly in an area with high groundwater infiltration levels.
In 2022, the storm discharges from waste water treatment works into Chichester Harbour totalled:
Chichester (Apuldram) – 87.33 hours (3.64 days)
Bosham – 791.54 hours (32.98 days)
Thornham – 585.02 hours (24.38 days)

In addition, data has also been supplied since 2020 for 5 CSO’s that discharge into the Harbour. The most significant of these in 2022 was Priors Leaze, Nutbourne, which discharged for a total of 8.03 days. It should be noted that the harbour also receives storm discharges via Budds Farm in Langstone and the Lavant WWTW.
It is very hard to foresee how Southern Water, given the current regulatory framework, will be in a position to provide the necessary infrastructure to accommodate the development levels proposed. Recent permitted developments in the district rely on removal of waste by tanker, to avoid back-flowing sewage.
Likewise in a region of water scarcity, which will only worsen in the future with climate change, the proposed level of development is utterly unsustainable. The water-recycling proposals at the Havant Thicket reservoir site are deeply unpopular with the local community.

The inclusion of the Nitrate Neutrality policy since the previous iteration of the Plan is welcomed and it will be important that the guidance is continually monitored and reviewed to ensure that it is fit for purpose and that mitigation measures are effective.

The housing allocation for the District needs to be significantly reduced, with less reliance on bringing forward greenfield sites.

We feel that the proposed volume of housing delivery is too high for the capacity of the district to deliver it sustainably, without causing significant harm to protected sites, landscapes and communities. The proposed development is squeezed into a small geographic area along the east-west corridor especially, sandwiched between the Chichester Harbour AONB and South Downs National Park, harming both through the loss of interconnectivity both in terms of biodiversity and landscape views. This concentrated development places an undue burden on the available infrastructure (particularly water treatment and road transport) and is an unsustainable use of highly productive farmland on the south coast plain. We believe this approach is incompatible with wider government ambitions around environmental and climate change management.

The housing allocation for the east-west corridor should be reduced, with particular reference to:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

The Chichester Harbour Trust objects to the proposed housing allocations, in particular with reference to the allocations below which principally affect Chichester Harbour AONB:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

The combined allocation for these sites is 1,595, and should be considered in combination with the 1,600 houses allocated in A6 West of Chichester, and 30 at Fishbourne Parish leading to a total of 3,225. Taking into consideration the 2,100 houses planned at Havant Borough Council's strategic site at Southleigh, this gives a total figure of 5,325 houses between Chichester and Havant in the gap between the AONB and National Park. This represents major development within the 5.6km zone of influence for Chichester Harbour SSSI.

It is our observation that these proposed allocations represent a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly:
Policy NE2 Natural Landscape
Policy NE3 Landscape Gaps between settlements
Policy NE6 Chichester’s Internationally and Nationally Designated Habitats
Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat
Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty
Policy NE16 Water Management and Water Quality

Our specific objections to the allocations at A11,12 and 13 relate to:
- the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure of over 5,000 homes (potentially over 10,000 people) within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

It is noted that in the case of A12 and A13, the location of the development is not yet clear as the sites will be determined through the neighbourhood planning process, however it is hard to see how the concerns raised above would not be relevant.

Overall, we feel that the Plan does not reflect emerging government rhetoric (soon to translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

A significant reduction in the housing allocation along the A259 corridor between Chichester and Southbourne and the removal of A11 Highgrove Farm allocated site in particular.

The housing allocations outlined in A11,A12,A13 seem to go directly against the guidance of policy P2 on local character and distinctiveness. Extensive development in the countryside, "bolted on" to existing settlements of Bosham, Chidham & Hambrook and Southbourne will inevitably fly in the face of the statement in 6.7 that "It is important to maintain the separate distinct identity of different settlements and a clear transition between built up areas and the countryside."
Most new developments witnessed in the district in recent years demonstrably do not deliver on these aspirations - they offer buildings of generic design that do not contribute to local settlement character or join with villages in a coherent way. This is all too visible along the A259 between Chichester and Southbourne.

Removal of A11 Highgrove Farm from the Plan

The Chichester Harbour Trust objects to the inclusion of A11 Land at Highgrove Farm, Bosham
This proposal represents major development adjacent to the Chichester Harbour AONB and within the 5.6km zone of influence for Chichester Harbour SSSI. It is our observation that this allocation represents a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly:
Policy NE2 Natural Landscape
Policy NE3 Landscape Gaps between settlements
Policy NE6 Chichester’s Internationally and Nationally Designated Habitats
Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty Policy NE16 Water Management and Water Quality

Our specific objections to the allocation at A11 relates to:
- the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

Overall, we feel that the allocation does not reflect emerging government rhetoric (which may soon translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

We would need to have a clearer idea of the location of the proposed development to comment more fully, however in principle we object to the proposed level of development for a village of this size and would wish for the allocation to be substantially reduced.

The Chichester Harbour Trust objects to the allocation at A12 Land at Chidham and Hambrook. This proposal represents major development adjacent to the Chichester Harbour AONB and is disproportionate to the size and facilities of the existing settlement.
It is within the 5.6km zone of influence for Chichester Harbour SSSI. It is our observation that this allocation represents a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly: Policy NE2 Natural Landscape Policy NE3 Landscape Gaps between settlements Policy NE6 Chichester’s Internationally and Nationally Designated Habitats Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty Policy NE16 Water Management and Water Quality

It is difficult to make an assessment of the impact of housing development in the broad location without specific site allocation plans, which we understand would come through the neighbourhood plan process. However our general concerns about the allocation relate to:
the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure at Thornham WWTW and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes - the additional recreational pressure within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

Overall, we feel that the allocation does not reflect emerging government rhetoric (which may soon translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

We would need to have a clearer idea of housing location to comment in more depth however would wish to see a reduction in the allocation at this location.

The Chichester Harbour Trust objects to the allocation at A13 at Southbourne. This proposal represents major development adjacent to the Chichester Harbour AONB and is disproportionate to the size and facilities of the existing settlement. It is within the 5.6km zone of influence for Chichester Harbour SSSI. It is our observation that this allocation represents a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly: Policy NE2 Natural Landscape Policy NE3 Landscape Gaps between settlements Policy NE6 Chichester’s Internationally and Nationally Designated Habitats Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty Policy NE16 Water Management and Water Quality

It is difficult to make an assessment of the impact of housing development in the broad location without specific site allocation plans, which we understand would come through the neighbourhood plan process. However our general concerns about the allocation relate to: - the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure at Thornham WWTW and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

Overall, we feel that the allocation does not reflect emerging government rhetoric (which may soon translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

We believe the plan should be withdrawn and significantly revised.

We believe the plan should be withdrawn and significantly revised.

Whilst we welcome this policy for development management, it should be noted that the delivery of the Plan is overly reliant on development in the countryside through the spatial strategy. Of the 3,225 homes proposed between Chichester and Southbourne, overwhelmingly they will be built on greenfield sites. We would hope to see much greater focus on delivery of brownfield sites and urban locations.