Chichester Local Plan 2021 - 2039: Proposed Submission

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 mechanisms are available to support the delivery of housing.

Revise approach toward BLD and pursue strategy of allowing some limited dispersal of development in suitable locations as the most sustainable strategy for the distribution of housing in Southbourne Parish over plan period.

The draft policy wording would result in a conflict between meeting the local housing needs of the District and the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text. Our client represents the freehold owners of the Land North of Penny Lane, Hermitage (c 5.4 ha), which has been identified as a ‘deliverable’ site within consecutive versions of the Chichester Housing and Employment Land Availability Assessment (HELAA). Our client welcomes the inclusion of this site within the Broad Location of Development (BLD) and has recently submitted a planning application on the site for up to 84 dwellings (CDC ref. SB/23/00024/OUT).

Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance.

Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities.

Notwithstanding the benefits of a single eastern extension in the mid to later years of the Plan period, as supported in previous drafts of the Southbourne Neighbourhood Plan, a number of smaller sites can collectively bring the benefits of a single major large-scale development. This approach would have the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly.

Smaller sites can also play an important role in sustaining key services and facilities within Hermitage, Southbourne and Emsworth, which have been in decline in recent years due to changing shopping habits and community displacement from increasing affordably gaps, in part due to constrained housing supply. In allowing such sites to come forward the Parish could also be facilitating new community infrastructure through the IDP and funded through CIL and / or S106 Legal Agreements.

We therefore encourage the Council to revise the approach toward the BLD and pursue a strategy of allowing some limited dispersal of development in suitable locations as the most sustainable strategy for the distribution of housing in Southbourne Parish over the Plan period.

With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

We support the Settlement Hub classification for Southbourne as the District’s third largest settlement (in population size) after Chichester and Selsey and joint fourth highest ranking settlement in terms of number of key services and facilities. The location of Southbourne within the East-West Corridor accounts for 84.2% of the housing provision for 2021-2039. With good access to the regional road network and public transport links Southbourne has a key role to play in meeting the District’s full local housing need.