Chichester Local Plan 2021 - 2039: Proposed Submission

In view of this, it is considered that Policy S1 should be altered as follows:

2. Reinforcing the role of Manhood Peninsular as a location for moderate growth and home to existing communities, tourism and agricultural enterprise.

East Wittering should also be added to the list of Settlement Hubs considered for new residential and employment development under Part 4. As a consequence, Employment could be deleted from the reference under 5b.

Please refer to the Attached Document.

An objection is raised to Policy S1 on the basis of the omittance of residential development at the Settlement Hub of East Wittering. East Wittering/Bracklesham is classified as a Settlement Hub and within the Chichester and Retail and Main Town Centre Uses Study (2018) as a ‘secondary service centre, providing a reasonable range of employment retail, social and community facilities serving the settlement and local catchment areas’. It is therefore one of the larger and more sustainable locations for development within the Chichester District.
As set out in the preamble, it should be noted that approximately a third of the existing settlement of East Wittering sits within the Parish of West Wittering. The Site which is subject to these representations (Land to the West of Church Road) whilst being within the Parish of West Wittering, is closely related to, and forms part of, the settlement of East Wittering and shares a boundary with this settlement. Therefore, when reference is made to the ‘Settlement of East Wittering’ or the ‘Settlement Hub of East Wittering’ this also includes the Land which is subject to these representations (and located within West Wittering Parish).The omission of new residential growth at the settlement of East Wittering has not been sufficiently ‘’justified’ given the stated objectives of the Plan to accommodate development in larger and more sustainable settlements. Provision for 600 new residential units had been included within the Preferred Approach version of the Local Plan, identifying this as a modest level of growth. This included 350 dwellings at East Wittering.

However, all growth scenarios for the Manhood Peninsula (with the exception of 50 dwellings at North Mundham) were deleted for the following reason:
“In conclusion, in light of the latest flood risk evidence , there is only one scenario for East Wittering and Bracklesham Parish, involving completions, commitments and windfall only.”

The Sustainability Appraisal has not tested a development scenario which includes development at the settlement of East Wittering (within either East or West Wittering Parish). This is considered to be a significant flaw to the SA and the overall Spatial Strategy in Policy S1.

It is noted within the SA that the 2022 SFRA shows extensive tidal flood risk under climate change scenarios, affecting all the sites reasonably in contention for allocation. This includes Site HWW0002a, Land to the West of Church Road.

However, Chichester District Council published another SFRA back in 2018, identifying Land to the West of Church Road, in the ‘climate change risk zone in 2115’ catchment. The 2018 SFRA was utilised to assess sites in the 2020 HELAA. Land to the West of Church Road was originally discounted in the 2020 HELAA, due to being in the subject catchment. This was challenged and it was argued that this is an extreme tidal event and should not be confused with identified flood zones. The EA subsequently advised that the model had been superseded and that the site is not considered to be at risk of coastal flooding. The reason for the difference was found to be which of the various flood risk scenarios were used in the 2018 SFRA. Chichester District Council then produced a revision to the 2018 SFRA in April 2021.

Upon review of the 2022 SFRA, the Council claims the assessments have an updated harbour costal model. Appendix E of the 2022 SFRA outlines how climate change may influence the tidal and coastal flood risk. However, from reading the 2022 SFRA, our interpretation is that the update is based on the original 2018 SFRA, instead of the revised 2018 SFRA and therefore, it appears that the modelling is inaccurate once again.


In the absence of the modelling data and clarification of the 2022 SFRA, we retain our rights to make future representation and participate in the examination, at the later stage of this Local Plan Review Process. Relevant Correspondence is attached at Appendix C.

Land West of Church Lane is therefore not affected by flood constraints and available for development within the HELAA. It is also noted that the Sustainability Appraisal considers notes a ‘green’ response on the RAG scale for flood Zone, and supports the findings that the site is suitable for development on these grounds.

Paragraph 3.20 of the Draft Plan sets out that several planning approvals have contributed to moderate levels of growth on the Manhood Peninsula. The Sustainability Assessment notes 256 dwellings on 5 sites within East Wittering and Bracklesham Parishes and suggests that other sites may also come forward on appeal.

It is none-the-less considered necessary to plan proactively and future allocations should be made at the settlement of East Wittering, given its sustainability (second only to Chichester) and aspirations for further retail, employment, tourism and leisure growth. Currently, the level of commitments falls below the 350 dwellings allocated in the Preferred Option version Local Plan and it is notable that these would also be delivered within the early stages of the Plan period.

Further growth would also contribute to the viability of services and facilities at the settlement of East Wittering, which is particularly important given the need to sustain these services for the older population that resides within the Manhood Peninsula.

Therefore, it is considered that further allocations should be made to secure modest future growth. In this context it is considered that the 350 dwellings allocated in the Preferred Option version Local Plan should be re-instated. Failing that, as a minimum, 150 -200 dwellings could be accommodated at the settlement of East Wittering (but within the Parish of West Wittering) to deliver a commensurate level of growth to that originally envisaged.

It is considered that this could be accommodated on the Northern Parcel on Land to the West of Church Road. The Southern Parcel has already been permitted - 70 dwellings on Appeal in April 2022 (Ref: APP/L3815/W/21/3286315). The Northern Parcel (Ref HWW0002a) could deliver circa 150 – 160 dwellings. The Details of this are set out under Objections to Policy H2 below.

Of further note, The 2021 census recorded a population of 6,059 persons for East Wittering Built Up Area, which is set out as including the Land to the West of Church Road.

Chichester District has an average household size of 2.4 persons. This means that the existing commitments of 256 dwellings would generate a population of circa 614 people. The Northern Parcel of Land to the West of Church Lane could contribute 150 dwellings or a further 360 persons. Overall, this would equate to a population rise of circa 974 persons (or circa 16%) within the Plan period and would constitute a moderate level of growth for this settlement and reflective of its size and the accessibility constraints.

The inclusion of East Wittering/Bracklesham as a Settlement Hub is supported.

As noted in our response to Policy S1, it is considered that residential growth should be planned for accordingly

The overall housing provision for the Plan Period should be the full OAHN of 763 dwellings per annum. This should include provision for 600 dwellings within the Manhood Peninsular as set out in the Preferred Option version of the Plan.

Whilst we acknowledge that Chichester District Council is positively attempting to address housing need within the District, we object to proposed plan area total of 10,359 dwellings and point out that this figure is too low when compared to the data provided within the HEDNA (April 2020). The objectively assessed housing need (OAHN) of 638 dwellings per annum should be met in full, particularly given the significantly higher medium house prices in Chichester, also set out within the HEDNA. Failing to meet the OAHN will lead to heightened problems of affordability and over-occupation within the District. It is therefore considered that the policy is not ‘positively prepared’.

It is also objected to on the basis that there is no firm allowance made for meeting the requirements of the South Downs National Park, which would be an additional 125 dwellings per annum in line with the HEDNA. It is therefore considered that the housing provision for 2021 – 2029 should be based on 763 dwellings per annum or a total of 13,734 dwellings. The Policy is therefore not ‘positively prepared’ in this regard unless such provision is made.

The supporting text for Policy H1 reads:

‘constraints, particularly the capacity of the A27 has led to the council planning for a housing requirement below the need derived from the standard method of 525 dpa in the southern plan area and a further 40 dpa in the northern plan area, a total supply of 10,350 dwellings over the plan period from 2021 – 2039’

Whilst acknowledging the ongoing delays to plans to upgrade the A27, objection also arises from the unbalanced nature of the strategy, which places 84% of housing growth within the east-west corridor, thereby focusing housing on the area of greatest transport infrastructure constraint. A more balanced spatial approach should be adopted with more land allocated within the South of the District, adjacent to Settlement Hubs, which would put less pressure on the A27.

The Preferred Approach version of the Local Plan included moderate growth for the Manhood Peninsula for 600 dwellings, including at the Settlement Hub of East Wittering for 350 dwellings (but within the Parish of West Wittering). As noted under objections to Policy S1, it is considered that the Manhood Peninsula, and the settlement of East Wittering in particular, can accommodate future, modest growth.

It is also acknowledged within the Sustainability Appraisal (January 2023) that there is clear support for development on the Manhood Peninsular, because there is not a requirement for nutrient neutrality (affecting much of the East-West corridor). Development would also support services which need to be bolstered in view of the significantly more elderly population here.

As noted under Policy S1, it is also considered that the data underpinning the SFRA (December 2022) is believed to be flawed and that there is capacity for development at the settlement of East Wittering accordingly. For the SA to exclude one of the most sustainable settlements in the District is considered ‘unjustified’ particularly when based on this flawed data.

Currently, the housing figure for the Manhood Peninsula is 963 dwellings and relies on existing commitments and windfalls only (apart from 50 dwellings at North Mundham). When annualised this provides only 53 additional dwellings per annum over the plan period which is not sufficient to meet the housing needs of this area. The reason for allocating North Mundham over more sustainable settlements in the Peninsular appears to be the incorrect assumptions on flood risk noted above.

Therefore, in terms of future growth it is considered for the reasons set out under Policy S1 that growth should be included within the Manhood Peninsular, at the previous level of 600 dwellings. Accordingly, this means that the broad spatial distribution of housing within the Manhood Peninsular should be at least 1,563 dwellings and not 963 dwellings as indicated.

We argue that to prepare a ‘justified’, ‘effective’ and ‘consistent’ Local Plan, the District needs to increase the housing provision within the Manhood Peninsular (in particular at the Settlement Hub of East Wittering) and provide for new allocations in addition to existing commitments.

An Allocation should be made within Policy H2 for 150 – 160 dwellings at Land West of Church Road (Northern Parcel). By not including an allocation at the settlement of East Wittering, and specifically Land West of Church Road (Northern Parcel), the Draft Local Plan is not ‘justified’ and ‘effective’

Following on from objections to Policies S1 and H1, a further objection is raised to the absence of strategic allocations at the Settlement Hub of East Wittering, which had been supported under the Preferred Approach of the Local Plan by Policy AL8 (350 dwellings to be delivered by the Neighbourhood Plan). However, a strategic allocation should be made at the Settlement Hub of East Wittering. It should not be deferred to the neighbourhood planning process as proposed in the Preferred Approach of the Local Plan as this would not be ‘positively prepared’.

As set out under objections to Policy S1, the Sustainability Appraisal has incorrectly not tested growth scenarios which includes development at the Settlement Hub of East Wittering. It is noted within the SA that the 2022 SFRA shows extensive tidal flood risk under climate change scenarios, affecting all the sites reasonably in contention for allocation. This includes Site HWW0002a, Land to the West of Church Road.

However, Chichester District Council published another SFRA back in 2018, identifying Land to the West of Church Road, in the ‘climate change risk zone in 2115’ catchment. The 2018 SFRA was utilised to assess sites in the 2020 HELAA. Land to the West of Church Road was originally discounted in the 2020 HELAA, due to being in the subject catchment. This was challenged and it was argued this is an extreme tidal event and should not be confused with identified flood zones. The EA subsequently advised that the model had been superseded and that the site is not considered to be at risk of coastal flooding. The reason for the difference was found to be which of the various flood risk scenarios were used in the 2018 SFRA. Chichester District Council then produced a revision to the 2018 SFRA in April 2021.

Upon review of the 2022 SFRA, the Council claims the assessments have an updated harbour costal model. Appendix E of the 2022 SFRA outlines how climate change may influence the tidal and coastal flood risk. However, from reading the 2022 SFRA, our interpretation is that the update is based on the original 2018 SFRA, instead of the revised 2018 SFRA and therefore, it appears that the modelling is believed to be inaccurate once again.

Land West of Church Lane is therefore considered available for development within the HELAA. The Sustainability Appraisal also considers the site under reference HWW0002a and has a ‘green’ response on the RAG scale indicated and supporting the findings that the site is suitable for development on these grounds.

It is therefore considered that the exclusion of the settlement of East Wittering from consideration for development is fundamentally flawed and based on incorrect data.

Specifically, Land to the West of Church Road (Northern Parcel) is identified within the SHLAA as developable (See Appendix A) and should be subject to a strategic allocation for 150 - 160 dwellings. Development on the site (Phase 1) is already part committed through the 2022 permission for 70 dwellings (Appeal Ref: APP/L3815/W/21/3286315), demonstrating the unconstrained nature of the overall site.

Representations were submitted via Chichester’s Call for Sites exercise in 2020, and the Site was positively assessed in the HELAA 2021and considered developable. Therefore, in total the Site could accommodate 220 to 230 dwellings, which accords with the HELAA assessment of 226 dwellings.

Notwithstanding this positive HELAA assessment in 2021, the assessment within the SA differs and refers to a relatively poor performance with specific reference to a low level of landscape performance within the 2019 Landscape Capacity Study. The 2019 Study predates the HELAA (and is arguably more out of date in comparison) and covers a more significantly larger area than site HWW0002a. The conclusions of the 2019 Landscape Capacity Study also recognise that there could be very limited development adjacent to the settlement edge if carefully integrated into the landscape and with care given to heritage assets. Given the findings of the Appeal Inspector (see below) it is considered that more significant development can be accommodated through the introduction of an appropriate landscaped setting and the conclusions of the SA are over played in this regard.

Notwithstanding the findings of the 2019 Landscape Capacity Study, during the consideration of the Appeal for the Southern Parcel in 2022, development was found to have a limited impact upon the wider landscape and whilst it would have a significant but localised effect on the character of the countryside, it was concluded this would lessen over time. It is considered that the development of the Northern Parcel could also be integrated into the landscape in a similar manner without significant, wider landscape harm.

Please also see Site Specific Representation Attached

Land West of Church Road (Northern Parcel) should be allocated for strategic development. Accordingly, the West Wittering Parish should be noted with a ‘*’

It is considered that ‘small-scale’ should be defined within the Policy, noting that 6 dwellings is the minimum for allocation but no guidance is given about when a site stops being ‘small-scale’ and becomes ‘strategic’ and to be included under Policy H2.

It is noted that West Wittering Parish is not apportioned development. As set out under objections to Policy H2 it is considered that Land West of Church Road (Northern Parcel) should be allocated for strategic development. Accordingly, the West Wittering Parish should be noted with a ‘*’