Chichester Local Plan 2021 - 2039: Proposed Submission

Please refer to the attached document for further information. Policy S1 is discussed on page 6 of attachment.

Please refer to the attached supporting document. Policy S2 is discussed on page 8.

Please refer to attached supporting document. Policy H1 is discussed on page 11.

Allocate a minimum of 300 dwellings to Loxwood. Remove the reliance on the delivery of housing via
Neighbourhood Plans and parish allocations.

Please refer to attached supporting document. Policy H2 is discussed on page 12.

The Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.

Please refer to attached supporting document. Policy H3 is discussed on page 13.

Please refer to attached supporting document. Policy A15 is discussed on page 14.

The site at Land South West of Willetts Way, is appropriate for up to 10 units and therefore fits the definition of ‘small scale housing developments’, as such is a target site for Policy S1.6.a.

Policy S1 – Spatial Development Strategy should be amended to include specific non-strategic allocations of land and remove the requirement for Neighbourhood Plans to deliver at this more local scale.

We acknowledge support of the allocation of Loxwood as a ‘Service Village’ given its proximity and connections to Billinghurst, and the local services and facilities available.
We also acknowledge, Point 6.a which allows small scale housing developments consistent with housing numbers set out in Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039. The site at Land South West of Willetts Way, is appropriate for up to 10 units and therefore fits the definition of ‘small scale housing developments’, as such is a target site for Policy S1.6.a.
An analysis of Policy H3 is discussed in greater detail below, however the reliance on Policy H3 and consequently Neighbourhood Plans, means that this policy is not ‘effective’ in that a dependence on individual Parishes to allocate housing to meet requirements/targets may not be met in a sustainable way and in sufficient time to meet local needs. This means that the housing targets established in Policy H2 may not be deliverable over the plan period.
It is considered that to fulfil its strategic role (particularly with the reduced housing requirement below OAHN) the draft Local Plan review must allocate individual housing sites across the District, including Non-strategic provision across towns, villages and Parishes.
The Draft Local Plan is therefore considered to be ‘ineffective’ and ‘unjustified' by failing to ensure the delivery of housing in an effective and timely manner. Policy S1 – Spatial Development Strategy should be amended to include specific non-strategic allocations of land and remove the requirement for Neighbourhood Plans to deliver at this more local scale.

The local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.

The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006).

As with Policy S1, we are in agreement with the Draft Local Plan defining Loxwood as a ‘Service Village’ in terms of settlement hierarchy with a need to direct growth to the most accessible and best-connected locations, including villages with good public transport options.
We seek to acknowledge the policy discussion on settlement boundaries, and support the presumption in favour of sustainable development within the settlement boundary of service villages.
However, we consider the Draft Local Plan to be ‘ineffective’ and ‘unjustified' in this respect by giving the power to define the Settlement Boundaries to Neighbourhood Plans. The Draft Local Plan cannot be ‘positively prepared’ when suitable, available and achievable sites are left fragmented and overlooked by Parish Councils creating piecemeal plots outside of the settlement boundary for often unjustified reasons, the Neighbourhood Plan process being subject to lesser scrutiny (having only to meet basic conditions) than local plans.
In line with our comments on Policy S1 – Spatial Development Strategy, the local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.
In relation to Loxwood for example, the settlement boundary as defined by the Neighbourhood Plan is not representative of the current village and its settlement, or suitably reflective of the levels of housing growth and allocations required. The current settlement boundary is shown below in the Settlement Boundary (Loxwood Neighbourhood Plan Reg 15) (Figure 4). The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006). The site is clearly sustainable, being close to the village centre, and associated services but was excluded for unjustified reasons through the previous Neighbourhood Plan process.
Furthermore, the settlement boundary also excludes the High Street and associated residential properties to the south of the village centre which are historically and currently part of the village. The historic map shown below (Historical Ordnance survey map dated 1912) shows the small settlement of Loxwood at that time with the junction of Station Road and the High Street and only a small number of properties but the residential dwellings on the High Street were central to the evolution of the village and close to services, facilities, surgeries and the school which grew around them. To exclude the High Street and land to the rear including Land South West of Willetts Way is illogical and unjustified.
Figure 6 indicates where the logical and justified settlement boundary should be to the south of Loxwood (represented by the red line). The inclusion of this area is both a sustainable allocation of 10 new homes at Land South West of Willetts Way, but also a more accurate reflection of the actual settlement boundary of the village, through the inclusion of the historic ‘High Street’.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan needs to specify the settlement boundaries and allocate sites, and not delegate to Neighbourhood Plans.

In line with our comments on Policy H1 – Meeting Housing Needs, we propose a greater allocation of dwellings to the sustainable settlement of Loxwood, with a minimum of 300 dwellings, based on the findings of the Sustainability Appraisal (Jan 2023).
In addition to this, we do not support the strategic allocation of housing at a Parish/Neighbourhood Plan level, and strongly object to proposed provision of 220 dwellings via parish allocations. This is based on the proposed settlement boundary within the Revised Neighbourhood Plan for Loxwood, not adopting appropriate sites for housing.

Policy H2 – Strategic Locations/Allocations should be remove the reliance on the delivery of housing via Neighbourhood Plans and parish allocations, and amend to allowed proposed dwelling allocations to be allocated at a District level, in order to ensure the uptake of appropriate deliverable sites.

We acknowledge that the figure of 220 dwellings for Loxwood has been assessed through an approximate blend of scenarios within the Sustainability Appraisal, however the higher growth scenarios allow between 450-1050 dwellings.
While we support the proposed growth of Loxwood, we wish to highlight that this proposed figure of 220 will not sufficiently meet the objectively assessed need for housing within the District, and should be increased to allow greater housing provision in the North of the Plan Area. In line with our comments on Policy H1 – Meeting Housing Needs, we propose a greater allocation of dwellings to the sustainable settlement of Loxwood, with a minimum of 300 dwellings, based on the findings of the Sustainability Appraisal (Jan 2023).
In addition to this, we do not support the strategic allocation of housing at a Parish/Neighbourhood Plan level, and strongly object to proposed provision of 220 dwellings via parish allocations. This is based on the proposed settlement boundary within the Revised Neighbourhood Plan for Loxwood, not adopting appropriate sites for housing.
The Sustainability Appraisal discusses the 10 unit site, HLX0006, and outlines that the site is considered to be suitable, available and achievable within the HELAA. As such, the SA has included the site within the calculated sum of anticipated future dwellings across Loxwood (220). However, the site has been disregarded within the Neighbourhood Plan and sits outside of the proposed settlement boundary, despite being a highly suitable location for housing allocation.
This Policy can therefore, not be considered ‘effective’ within the Draft Local Plan as the housing provision of 220 can be increased to better satisfy the objectively assessed housing need in of the District. Further to this, the Parish Council’s failure to include and allocate appropriate sites at a Neighbourhood Plan level will mean that the housing target of 220 dwellings will not likely be deliverable across the plan period.
The Draft Local Plan is therefore considered to be ‘ineffective’ and ‘unjustified' by failing to provide sufficient housing provision or ensure the delivery of housing in an effective manner. Policy H2 – Strategic Locations/Allocations should be remove the reliance on the delivery of housing via Neighbourhood Plans and parish allocations, and amend to allowed proposed dwelling allocations to be allocated at a District level, in order to ensure the uptake of appropriate deliverable sites.

Whilst it is agreed that Loxwood should be subject to non-strategic housing allocations, we cannot support this Policy H3, based on its reliance on Policy H2 and neighbourhood plan allocations.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.

It is acknowledged that Loxwood is marked with an ‘*’ outlining that a strategic location has been identified via a neighbourhood plan within Policy H2.
This is discussed in greater detail under Policy H2 representations, however, we consider the approach of housing allocation and defining settlement boundaries via neighbourhood plans and parish allocations to be ‘ineffective’ and ‘unjustified’.
In relation to Loxwood for example, the settlement boundary as defined by the Neighbourhood Plan is not representative of the current village and its settlement, or suitably reflective of the levels of housing growth and allocations required. The current settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006). The site is clearly sustainable, being close to the village centre, and associated services but was excluded for unjustified reasons through the previous Neighbourhood Plan process.
The Draft Local Plan cannot be ‘positively prepared’ when suitable, available and achievable sites are left fragmented and overlooked by Parish Councils creating piecemeal plots outside of the settlement boundary for unjustified reasons, while the Neighbourhood Plan process is subject to lesser scrutiny (having only to meet basic conditions) than local plans.
Whilst it is agreed that Loxwood should be subject to non-strategic housing allocations, we cannot support this Policy H3, based on its reliance on Policy H2 and neighbourhood plan allocations.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.