Chichester Local Plan 2021 - 2039: Proposed Submission

In principle, Gladman support the Local Plan’s vision which sets out how the area will grow and evolve over the plan period. Gladman support the acknowledgement that Chichester will lead sustainable development in the area and the emphasis placed on Chichester as a regional city and major economic driver for the district.

Gladman support the continued stance the Council is taking against mitigating against climate change taking account of factors such as sea level rise, higher summer temperatures and the need to reduce greenhouse emissions.

Gladman recognise the importance of new development opportunities to provide appropriate mixes of housing types, sizes and tenures to meet the identified housing needs of the area. It is important to note that the housing mix as identified in the Council’s latest evidence base only represents a snapshot in time in relation to the current housing needs.

As such, the policy should provide for flexibility going forward so that the Plan is able to respond to changes in circumstances at the time of an application being submitted to the local planning authority so that development opportunities can make better use of the land available whilst responding to the housing needs at that time. In this instance, Gladman support the general approach of the policy, particularly sub-criterion 3 which allows flexibility within the mix and variety of dwellings sizes for market dwellings.

In principle, Gladman support the intentions of the above policy as this is in line with Government thinking to provide opportunities for custom and self-build housing. We are encouraged to see that the Council is opting for a 12-month marketing period before plots may be built out as conventional market housing. It is generally accepted that a period of 12 months is normally required in Local Plans where plots can revert back to the developer for alternative forms of housing.

Gladman support the current approach of draft Policy H4 which proposes different levels of affordable housing provision depending on location within the district as assessed within the Housing and Economic Development Needs Assessment 2022 (HEDNA) and the viability. Gladman further welcome the flexibility within the policy which allows for reduced rates of affordable housing where viability concerns exist.

Gladman support the provision of affordable housing on site but consider that all affordable housing requirements are tested thoroughly to ensure that they are viable and deliverable alongside the other policy requirements of the Local Plan. The Local Plan should consider that the NPPF determines a minimum affordable housing requirement of 10%, and that it is preferred that a proportion of affordable housing are First Homes.

The supporting text also details the overall housing mix for residential development as defined by the HEDNA 2022. Gladman recognise the need to ensure that a mix of house types, sizes and tenures are delivered to support choice and competition, but consider that the policy requires a degree of flexibility to ensure the provision reflects local need, site characteristics and market aspirations.

The Council will need to clearly set out in draft Policy NE5 the extending timetable being given to small sites to ease the burden on small developers and LPAs. The Government’s response to the consultation on the regulations for and implementation of BNG outlines that implementation of BNG on small sites will be extended to April 2024.

In addition, the policy wording should allow for off-site BNG provision to be delivered on land outside of the local planning authority area that is controlled by either applicants or other landowners, or for a solution to be delivered via a BNG company. An off-site solution, which is accepted as being appropriate in principle by some local authorities, is where the identified biodiversity (habitat) units required to deliver BNG would be secured through a BNG company such as the Environment Bank. These units would be secured through a satisfactory legal framework and appropriately worded planning condition would be attached to the planning permission.

he NPPF encourages new trees being incorporated into new developments and the Environment Act suggests that biodiversity can be increased through creation of green corridors, planting more trees or forming local nature spaces, there is no minimum requirement for tree planting.

Gladman consider a 10% Biodiversity Net Gain (BNG) target to be appropriate for the district as it complies with national guidance within the Environment Act which seeks a 10% BNG. The costs of delivering BNG varies significantly depending on the level of biodiversity on a site and can significantly impact viability.

Criterion 1d) of draft Policy NE5 refers to a ‘last resort’ scenario for developments for providing BNG by purchasing credits for through the national biodiversity credit scheme. The policy wording should allow for off-site BNG provision to be delivered on land outside of the local planning authority area that is controlled by either applicants or other landowners, or for a solution to be delivered via a BNG company.

An off-site solution, which is accepted as being appropriate in principle by some local authorities, is where the identified biodiversity (habitat) units required to deliver BNG would be secured through a BNG company such as the Environment Bank. These units would be secured through a satisfactory legal framework and appropriately worded planning condition would be attached to the planning permission.

15% above the housing requirement should be identified to safeguard against the non-implementation and delivery of housing proposals and to ensure the Plan is effective and positively prepared.
Higher number of homes should be allocated to the Manhood Peninsula.

The table included within Policy H1 shows an overall housing supply of 10,359 dwellings over the 2021-2039 plan period. This equates to a flexibility allowance of just 0.087%. Further flexibility needs to be built into the housing supply to allow for any phasing issues and an element of non-delivery of sites. The Levelling-up and Regeneration Bill: reforms to national planning policy consultation noted that their analysis suggests 15% of planning permissions are not progressed or are revised.

In this regard, Gladman consider that an additional supply flexibility of 15% above the housing requirement should be identified to safeguard against the non-implementation and delivery of housing proposals and to ensure the Plan is effective and positively prepared in line with paragraph 35 of the NPPF. This would result in the Council needing to identify a further 1,550 homes over the plan period.

Gladman strongly disagree with the no. of homes allocated to the Manhood Peninsula. The 963 dwellings figure over the plan period comprises of existing housing completions and commitments in the area and it does not include any new strategic housing allocations. The Council maintain that is due to recognition of the recently permitted growth and the on-going constraints in the area such as groundwater flood risk. The reason why there is a high no. of commitments in the area in recent years is due to Chichester District Council currently being unable to demonstrate a robust five-year housing land supply.

A small amount of allocated housing growth has been allocated to the Manhood Peninsula area of the district due to the uncertainty surrounding the impact of groundwater flood risk in the area, following the publication of the revised PPG guidance on flood risk and coastal change (August 2022). A high-level data map was produced by JBA Consulting which indicates likely groundwater levels across the district taking into account factors such as topography, groundwater recharge volumes and spatial variations in aquifer storage and transmission properties. Whilst this provides a useful starting point for any assessment of groundwater flood risk, it does not necessarily assess the risk of groundwater flood risk.

Gladman’s land interest at land off Main Road, Birdham lies in the Manhood Peninsula area. An outline planning application was submitted by Gladman in June 2021 and is currently under determination by the Council (application ref: 21/01830/OUT). Gladman have recently submitted a Groundwater Flood Risk Assessment (GFRA) which concludes that the site is at negligible risk of groundwater flooding at ground level and low to moderate risk below ground level with appropriate mitigation where required. The GFRA is currently subject to review by the Lead Local Flood Authority and if a no objection response is submitted, the application will be reported to Chichester’s Planning Committee with no outstanding technical issues likely to be in April 2023.

Furthermore, Gladman have concerns that progressing with the proposed housing requirement in its current form will further exacerbate the significant shortage of affordable homes within Chichester and increase affordability issues in the district. The ratio of house prices to earnings in 2021 for Chichester is 14.61 and is therefore one of highest in the country.

Further housing growth in Birdham.

Gladman strongly disagree with the Council providing no new housing allocations in Birdham which is a Tier 3 Service Village. In the Preferred Approach consultation document, Birdham was allocated to deliver 125 new homes over the local plan period and now it is allocated to deliver 0 homes over the plan period.

There have been a few planning applications submitted for residential development in Birdham over the past few years. Gladman’s planning application at land off Main Road, Birdham is waiting to be reported to Chichester’s Planning Committee. The application site is highly sustainable and logical site in the district which is not currently subject to an adopted allocation or a draft allocation. In light of this conclusion, it seems illogical that the Council will not allocate any further housing growth to a highly sustainable settlement which can accommodate additional housing growth. This will ultimately result in affordability rising across the district and most notably in the northern area of the district.

See comments above

The Standard Method is a minimum annual housing need figure and should be considered a starting point. The PPG outlines that there are circumstances when it is appropriate to consider a higher housing requirement, including growth strategies, strategic infrastructure improvements, unmet need from neighbouring authorities or where previous assessments have indicated that need is significantly greater than the standard method indicates.

Draft Policy H1 seeks to provide a housing requirement for Chichester of 10,350 dwellings over the plan period 2021-2039, equivalent to 575 dwellings per annum (dpa). This comprises 535dpa in the southern area and 40dpa in the northern area of the district. This results in a shortfall of 63dpa over the course of the plan period, which equates to shortfall of 1,134 homes over the 18-year plan period.

Gladman have serious concerns that the Council are not planning to meet its housing needs in full. The Local Housing Need, as calculated by the Government’s standard methodology, sets out an annualised housing requirement of 763 dwellings per annum for Chichester. As a significant portion of the district falls inside the South Downs National Park authority area, this reduces the annualised housing requirement by 125dpa. Therefore, this results in the LHN for Chichester district totalling 638dpa.

The reason given by the Council for not meeting needs is principally infrastructure capacity – in particular the A27 and the cost of the proposed improvements being beyond what can be provided through development and there being no other sources currently available. The Council maintain that the 535dpa is based on detailed discussions with National Highways and the County Council as to what can be delivered within existing highway capacity. Whilst Gladman understands the concerns with regard to the need to improve local transport infrastructure, we note that the Council’s latest Transport Study (published in January 2023) undertook a sensitivity analysis as to whether the core scenario that supports the 535dpa position in the Draft Local Plan could accommodate a higher level of growth. The conclusion in paragraphs 5.6.5 and 11.2.3 of the Transport Study '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.'

The spatial strategy seeks to focus on delivering sustainable growth opportunities across Chichester to meet the need for homes and jobs for current and future generations.

The spatial strategy includes four tiers from the ‘Sub-Regional Centre’ at the top to ‘Rest of the Plan area’ at the bottom. The majority of new growth opportunities are concentrated towards the main urban areas of Chichester city and the Settlement Hubs (East Wittering / Bracklesham, Selsey, Southbourne and Tangmere) as well as settlements that support their roles with the remaining growth allocated across Chichester.

In principle, Gladman support the Council’s approach in seeking to focus development towards the most sustainable towns and villages capable of accommodating new growth opportunities. In particular, Gladman support the identification of Birdham as a ‘Service Village’, however we do have serious concerns in relation to the amount of growth which has been allocated to Birdham and the wider Service Villages in general (as discussed in more detail in response to draft policies H1 and H3). Development should be encouraged at the Service Villages which will enhance their roles through the provision of housing, employment, retail and other key services opportunities via allocations proposed through the emerging Chichester Local Plan.

The Council’s latest Transport Study published in January 2023 has identified that all other housing development which comes forward which is not allocated will have to pay a levy of £7,728 per dwelling which is a substantial increase per dwelling from the £1,402 per dwelling levy set out in the Planning Obligations and Affordable Housing SPD (2016) towards improvements to the Fishbourne Roundabout and the Bognor Road Roundabout. Gladman have concerns that this significant increase in the levy from the Planning Obligations and Affordable Housing SPD is going to make some speculative applications for small and medium housing sites unviable. For Gladman’s scheme at land off Main Road, Birdham, a residential scheme for up to 150 dwellings, this would equate to a financial contribution of £1,159,200 (£7,728 x 150 dwellings).