Chichester Local Plan 2021 - 2039: Proposed Submission

Wates considers that the LP, in its current form, is unsound because it is not; positively prepared, justified, effective or consistent with national policy.

In addition, we have concerns about the way in which the Council have approached the DTC, specifically with respect to employment land issues.

Wates request that the Council review their evidence base and ensure it is updated to deal specifically with the needs of the logistics sector.

The Council’s own evidence base points to an extreme undersupply of industrial floorspace. Wates believes that the Council should be looking at employment land in a more positive and proactive way and that more employment land needs to be allocated in order to ensure the LP is sound and the associated economic benefits associated with this can be realised.

Land at Badger Farm should be allocated for commercial development as it is an unconstrained site with good links to the Strategic Road Network and which can be delivered in a short timescale, contrary to the majority of the sites the Council are currently relying on to meet their employment needs.

Introduction and Site Details

Established is 1897, the Wates Group is one of the leading privately-owned construction, residential development, and property services businesses in the UK.

Everything we do is guided by our purpose of working together to inspire better ways of creating the places, communities, and businesses of tomorrow. Now in its fourth generation of family ownership, the Wates Group is committed to the long-term sustainability of the built environment.

Wates is promoting land at Badgers Farm, Hunston for commercial development. The site itself is currently used for equestrian purposes and extends to approximately 9 acres and is located at the northern end of the village, with good links to the A27. A site location plan is enclosed within these representations [TO BE EMAILED SEPERATELY]

The site is located within close proximity to Chichester and is easily accessible by foot, bicycle and public transport.
There are no constraints in bringing forward the site for development and Wates consider that the site should be allocated for commercial development in the Chichester Local Plan 2021-2039.

Duty to Co-operate

Whilst we note the Council have held ongoing discussions with key stakeholders and neighbouring Local Planning Authorities, it is noted that substantial reliance on demonstrating that the Duty to Cooperate (DTC) has been met appears reliant on several Statements of Common Ground (SOCGs) which are yet to be agreed and details are thin on the ground.

We do not wish to raise issues with the legal compliance with respect to the DTC, the lack of agreed outcomes as part of this process does cause issues with respect to the Local Plan (LP) being effective and positively prepared.

Employment is a key driver for the success of any Local Plan and yet, other than being part of a sub-Regional partnership, there is virtually no mention of this issue in the Council’s DTC Statement. Where employment issues are mentioned, the meetings referred to with neighbouring authorities took place some time ago and these can’t purport to reflect the most up to date position.

No doubt the Council will argue that SOCGs will be signed in due course (which will provide more detail) and will be before a Local Plan Inspector for their consideration. It is our view that, in order for the LP to be effective, this information should be available at this Regulation 19 stage.

Positively Prepared

The LP cannot be said to be positively prepared because it will not meet the Council’s identified housing needs. This has knock on implications for the consideration of the employment floorspace need over the plan period, because there is a direct relationship between the number of new homes being provided and associated growth scenarios which are being considered in relation to understanding future employment floorspace needs.

The LP is also reliant on the South Downs National Park Authority (SDNPA) agreeing to meet 15% of the Council’s employment needs (paragraph 12.64 of HEDNA, April 2022). In our view, given the Statutory Duties the SDNPA are under, this is an entirely unrealistic assumption to make. There is no mention of this issue in relation to the DTC Statement the Council have produced, which suggests no formal agreement is in place between the two Authorities.

Justified

We consider that the Council is taking an unduly pessimistic approach to future employment growth and the associated economic benefits this can bring to the District. In particular, the Council seem heavily reliant on the April 2022 update to the HEDNA. The data associated with this document naturally takes into account the economic impacts of Covid.

In our view, reliance on this data is not appropriate, given it was clearly a unique event with significant global impacts. It should not be relied upon for a LP which looks forward for a substantial period of time, because it downplays the need for employment floorspace.
We consider it more appropriate for reliance to be placed upon the 2020 HEDNA, which identified a need for 25.6 hectares of employment land, rather than the 23 hectares identified in the 2022 HEDNA update.

It is noted that, in January 2019, the Council identified a need for 27.7ha of employment land (Background Paper: Economic Development and Employment).

In addition, 15% should be added to these figures discussed above to ensure the Council are not reliant on SDNPA to deliver their employment needs.

Effective

As discussed above, we do not believe that effective joint cross-boundary working has taken place.

The Local Plan, as it currently stands, will not be effective in delivering the employment needs of the District.

Given that the 2022 HEDNA update repeatedly identifies that there is an ‘extreme undersupply’ (paragraphs 80, 83, 10.67, 10.74), with paragraph 10.110 noting that this is due to both strong recent demand and low levels of delivery - delivering the employment needs for the District should be of paramount importance to the Council.

Furthermore, we do not believe that the employment sites identified in the LP will necessarily be deliverable; specifically, the proposed new allocation A20. The Council acknowledge that there are deliverability issues because the site is anticipated to come forward in the latter part of the LP period.

This because the northern end of the site will play a key role in delivering any improvements to the Strategic Road Network (SRN) which are needed in the future. It is not clear to what extent this site is reliant on any improvements in the SRN in order to come forward.

Upgrades to the SRN in and around Chichester have a long and troubled history, to the extent that previously a local consensus could not be achieved which resulted in a funding package on offer to help facilitate the necessary improvements being withdrawn.
It is our view that in the absence of the necessary certainty in this regard, site A20 should not be identified for development.

Compliance with National Policy

Both the LP and its associated evidence base are completely silent on the logistics industry, contrary to National Planning Guidance.
Paragraph 031 (Reference ID: 2a-031-20190722) of the Planning Practice Guidance (PPG) specifically identifies that “The logistics industry plays a critical role in enabling an efficient, sustainable and effective supply of goods for consumers and businesses, as well as contributing to local employment opportunities, and has distinct locational requirements that need to be considered in formulating planning policies (separately from those relating to general industrial land).”

The PPG expects active engagement with logistics developers and occupiers to understand their needs, alongside analysis of market signals and economic data. This should then inform the needs with respect to the logistics industry and LPAs should then go on to identify how this need can be met.

In April 2022 the ONS published a report entitled “The rise of the UK warehouse and the golden logistics triangle” which identifies that the number of premises used for B8 storage and distribution uses has almost doubled in the last decade, with this rise accelerating in the last two years due to Brexit and the COVID-19 pandemic.

The chart below [TO BE EMAILED SEPERATELY] shows “Transport and Storage” to be the fastest growing industry group (both recent and long term) nationally, with an 88% increase from 2011-2021 and a 21% increase from 2019-2021.

This is supported by the June 2022 report by Frontier Economics “The Impact of Logistics Sites in the UK” which highlights in Chapter 2 that logistics has been the fastest growing sector across the UK in terms of jobs since 2012 (Table 3 p.27).

The Council’s reliance solely on employment projections fundamentally underestimates the performance of the logistics sector, and using those as the only base for determining land requirements, will always lead to a misunderstanding of sector needs and therefore land allocations that will not fully address needs.