Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A15 Loxwood
Representation ID: 3917
Received: 07/03/2023
Respondent: Loxwood Parish Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
At Examination the 220 allocation should be looked at in detail and the Inspector should be satisfied that the allocation is sustainable due to not only water neutrality constraints but also lack of capacity in the sewerage infrastructure within the Parish and surrounding area. Inundation of the system releases sewerage into gardens. The speculative development which has arisen uses a cesspit solution for the removal of sewerage from new homes. The traffic to be generated feeding onto the B2133 running through the village is a concern for a road which is already dangerous for pedestrians walking on narrow pavements.
LPC have already produced a Revised Neighbourhood Plan which allocates 126 houses plus 17 carried forward from the Made Neighbourhood Plan giving 143 houses. It has reached Regulation 14 consultation stage and is based upon the Preferred Approach Local Plan consultation. The residents of the Parish and Loxwood Parish Council have satisfied themselves through evidence gathered that 126 homes is a sustainable allocation given the constraints that exist.
This approach will conserve all the hard work put in by Loxwood Parish Council in producing its Revised Neighbourhood Plan and restore the confidence that Loxwood residents have in the Neighbourhood Planning Process.
Policy A15 should be removed and Policies H2 and H3 amended to reflect an allocation of 125 houses
Loxwood Parish Council has a number of concerns regarding Policy A15 of the emerging CDC Local Plan.
Loxwood Parish Council was advised of an estimated housing allocation of 125 homes in 2021 upon which it based a Revised Neighbourhood Plan which has been consulted upon at Regulation 14. This consultation gave rise to a submission plan which was submitted to CDC at Regulation 15. The revised Neighbourhood Plan did not proceed beyond Regulation 15 to Regulation 16 as housing numbers could not confirmed at that time by CDC due to the water neutrality issue.
CDC sent a letter to the north eastern parishes dated January 2022 laying out 5 scenarios for growth to be tested and evidence gathered. The results although promised for easter 2022 were not forthcoming until January 2023 due to the problem of establishing a mitigation strategy for water neutrality.
The mitigation strategy for water neutrality relies heavily on investment by southern water. Southern water in the past have neglected infrastructure in the district and have not set aside capital provision for such investment in their current 5- year infrastructure plan. They have accepted the mitigation strategy but Parishes have little confidence in delivery.
Loxwood Parish Council was surprised to be informed that the allocation of housing to their parish in the light of this water shortage for the area, was an additional 95 homes from what was envisaged before the realisation of the water neutrality issue. In addition, on top of the 220 homes to be found Loxwood Parish Council has suffered, in the interim, from speculative development amounting to 91 homes where planning was given permission before 1st April 2021 but outside of the Made Neighbourhood Plan due to a lack of five- year housing supply within the district.
Loxwood Parish Council ask that at Examination the 220 allocation be looked at in great detail for sustainability and that the Inspector satisfies him or herself that the allocation is sustainable due to not only the water neutrality constraints but also due to the lack of sewerage infrastructure that exists within the Parish and surrounding neighbours. Frequent inundation of the system releases sewerage into gardens. The speculative development which has arisen recently has returned to a cesspit solution for the removal of sewerage from these new homes. These developments have been unable to connect to the sewerage system over lack of capacity. Unbelievably Southern water have no plans for an upgrade of the system in the near future despite this archaic situation.
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.
Policy A15 criteria 9 requires that development is phased to ensure that sufficient wastewater disposal capacity is available to accommodate the requirements arising from new development. Southern Water are supportive of the policy wording and the Statement of Common Ground on Wastewater has been updated to reflect the latest position. Storm overflow performance improvements and infiltration reduction are planned for the 2020 – 2025 period and Loxwood WTW is included in PR24 for a growth scheme for AMP8 (2025 – 2030) which means that works are programmed to increase capacity at the works. The trajectory phases development in Loxwood towards the later part of the Plan period to allow for these works to take place.
The Transport Assessment concluded that there would be an insignificant impact on safety arising from development numbers at Loxwood and that the traffic impacts were acceptable.
