Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H1 Meeting Housing Needs
Representation ID: 4753
Received: 17/03/2023
Respondent: Elivia Homes (formerly Seaward Strategic Land Ltd) and Owners of Land on Durbans Road, Wisborough Green
Agent: Luken Beck MDP Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The District’s local housing need and the development strategy is ‘unsound’. The policy requirement to deliver 10,359 dwellings / 575 dwellings per annum, (dpa) over the Plan period (2021-2039), is derived from a supressed objectively assessed need of 11,497 / 638 dpa. Whereas this is referred to in paragraph 5.2 of the supporting text as a result of constrained highway capacity on the A27 there is provision within draft Policy I1 of the Proposed Submission Draft Local Plan and the associated Infrastructure Delivery Plan (IDP) to ensure the infrastructure and funding are available to support the delivery of housing.
The supporting text states the Council have made no provision to accommodate the unmet needs of the adjoining and other Local Authorities such as Arun District Council, who persistently fail to meet their housing delivery targets. The policy is therefore not considered to be positively prepared or consistent with national policy.
Paragraph 61 of the NPPF requires strategic policies to identify a minimum number of homes, through undertaking a standard method of assessment, unless there are exceptional circumstances to justify an alternative approach which also reflects current and future demographic trends and market signals.
The Council have not sufficiently evidenced the lack of capacity within the A27, the potential to alleviate pressure on the A27 through relocating some of the East-West Corridor growth proposals (i.e. to the North of the Plan Area) in order to fully justify a departure from the standard methodology. The proposed policy wording is therefore not considered to be positively prepared, consistent with national policy nor will it be effective in delivering the District’s full local housing need in sustainable locations, such as the Settlement Hubs and Service Villages.
We therefore request the Council review the approach towards meeting the full local housing needs of the District and plan for an increased supply of housing over the Plan period, in particular within the early years of the Plan.
The District’s local housing need and the development strategy is ‘unsound’. The policy requirement to deliver 10,359 dwellings / 575 dwellings per annum, (dpa) over the Plan period (2021-2039), is derived from a supressed objectively assessed need of 11,497 / 638 dpa. Whereas this is referred to in paragraph 5.2 of the supporting text as a result of constrained highway capacity on the A27 there is provision within draft Policy I1 of the Proposed Submission Draft Local Plan and the associated Infrastructure Delivery Plan (IDP) to ensure the infrastructure and funding are available to support the delivery of housing.
The justification for not meeting the housing needs in full is set out in the Housing Need and Transport Background Papers. The latest Duty to Cooperate evidence is set out in the updated Statement of Compliance.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039
Representation ID: 4755
Received: 17/03/2023
Respondent: Elivia Homes (formerly Seaward Strategic Land Ltd) and Owners of Land on Durbans Road, Wisborough Green
Agent: Luken Beck MDP Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Our client is fully in agreement with the Council’s Vision and Strategic Objectives, with regard to the dispersal of growth to the more sustainable rural villages. However, the limited housing provision for Wisborough Green of 75 dwellings, against the 220 dwellings proposed for Loxwood (draft Policy H2) is not considered to be reflective of the constraints and sustainability credentials of these settlements.
Our client has prepared a Vision Document as part of a strategic promotion of the Land on Durbans Road (located on a relatively unconstrained site on the northern edge of Wisborough Green), which is attached in support of this representation. The Vision Document demonstrates there is sufficient capacity to deliver c. 50 additional dwellings within comfortable walking distance, via safe and convenient walking routes, of a range of local amenities. The Council have not fully justified the disproportionate level of housing for Loxwood against that of Wisborough Green and on this basis the draft Plan is at greater risk of being found ‘unsound’.
Our client is fully in agreement with the Council’s Vision and Strategic Objectives, with regard to the dispersal of growth to the more sustainable rural villages. However, the limited housing provision for Wisborough Green of 75 dwellings, against the 220 dwellings proposed for Loxwood (draft Policy H2) is not considered to be reflective of the constraints and sustainability credentials of these settlements.
The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper.
As set out in the SA and Housing Distribution Background Paper a range of scenarios were considered in the north plan area and the final scenarios are the most appropriate for each settlement when taking into account the full range of factors needing to be considered.
Promotion of site noted.