Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S1 Spatial Development Strategy

Representation ID: 3911

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.


Our response:

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S2 Settlement Hierarchy

Representation ID: 3912

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.


Our response:

Where a Neighbourhood Plan is being prepared then it is considered appropriate that a review of the settlement boundary is undertaken as part of that review. A methodology for undertaking a boundary review, which is available to Neighbourhood Plan groups to use, is set out in the Settlement Boundaries Background Paper (May 2024).

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H1 Meeting Housing Needs

Representation ID: 3913

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Whilst we acknowledge the constraints of the A27 to the Southern Plan Area, these constraints are not as limiting in the North of the Plan Area, to justify a housing supply of 40 dwellings per annum (679 total).

It is therefore considered that a higher number of dwellings should be allocated to the North of the
Plan Area, by increasing the settlement boundary of sustainable settlements such as Loxwood and
Kirdford, in order to help the District achieve the objectively assessed housing need of the district.


Our response:

As set out in the Sustainability Appraisal (SA) and Housing Distribution Background Paper a range of scenarios were considered in the north plan area, including a higher growth figure for Loxwood, but not considered appropriate.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H2 Strategic Locations/ Allocations 2021 - 2039

Representation ID: 3914

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.


Our response:

As set out in the Sustainability Appraisal and Housing Distribution Background Paper a range of scenarios were considered in the north plan area, including a higher growth figure for Loxwood, but not considered appropriate.

The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period. The council would use a further DPD as a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Representation ID: 3915

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

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.


Our response:

The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period.

The council would use a further DPD as a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy A15 Loxwood

Representation ID: 3916

Received: 07/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

As has been discussed across these Draft Local Plan Representations, we support the proposed growth of Loxwood. However, we wish to object to Policy A15, highlighting that the proposed figure of 220 dwellings will not sufficiently meet the objectively assessed need for housing within the Chichester District.
This figure 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).


Our response:

See response to representations under H1 in relation to overall level of housing.
Work has had to be undertaken to look at the capacity of the north-east of the plan area to accommodate more dwellings, due to the constraints on growth in the south of the plan area (to demonstrate that the council has left ‘no stone unturned’ in seeking to reach the full local housing need figure). The outcome of this work, as set out in the Sustainability Appraisal (2023) and Housing Distribution Background Paper was that 220 is an appropriate figure for Loxwood parish to accommodate

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S1 Spatial Development Strategy

Representation ID: 3922

Received: 08/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

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.


Our response:

Where the Local Plan makes a parish housing requirement it will be for a Neighbourhood Plan to identify potential development sites.

It is noted that part of the submitted site now has planning permission for 5 dwellings (23/01104/FUL, permitted August 2023).

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Representation ID: 3923

Received: 08/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site submission Land South West of Willets Way, Loxwood.


Our response:

The Housing Distribution Background Paper (May 2024) sets out the justification for the site allocations and strategic parish numbers set out in Policy H2 (which includes Loxwood - so Loxwood does not have a number in H3).
Promotion of site noted.

Any settlement boundary changes will be considered through a neighbourhood plan

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H2 Strategic Locations/ Allocations 2021 - 2039

Representation ID: 3925

Received: 08/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.


Our response:

As set out in the Sustainability Appraisal and Housing Distribution Background Paper a range of scenarios were considered in the north plan area, including a higher growth figure for Loxwood, but not considered appropriate.

The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper.

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period.

The council would use a further DPD as a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Representation ID: 3926

Received: 08/03/2023

Respondent: Loxwood (Mellow) Ltd

Agent: Ms Megan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.


Our response:

The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period. The Site Allocations DPD provides a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

Promotion of site noted.

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