Chichester Local Plan 2021 - 2039: Proposed Submission

Paragraph 10.20 accurately summarizes the proposals for the second phase of development with one exception – the pavilion associated with the playing pitches has been provided in full as part of the phase 1 permission and sized to accommodate phase 2 requirements. The full sized pavilion is currently being built out. The paragraph should be amended to reflect this.

To avoid confusion and compliance with the NPPF, this bullet point should be updated to reflect criterion 13 of the Policy A6 wording.

To avoid confusion and compliance with the NPPF, this bullet point should be updated to reflect criterion 13 of the Policy A6 wording. The proposals are designed to maintain Green Field run off rates and does not increase flood risk off site, taking account of climate change. It does this by utilizing high quality Sustainable Drainage features which attenuate surface water whilst providing landscape and ecological benefits. There is no NPPF requirement to reduce flows below Green Field run off rates and to do so could have unintended consequences. The bullet point should be updated to reflect the NPPF requirements.

Miller and Vistry suggest criterion 14 needs clarifying. Miller Vistry agree that ensuring effective arrangements are in place to deal with foul drainage is an important consideration. Working with Southern Water, the development will connect to a new pipeline effectively conveying foul drainage to the Tangmere Wastewater Treatment Facility which has recently been upgraded. Similarly, Miller and Vistry agree that high environmental standards should be applied to the treatment of sewage arising from all development, however this is a matter beyond the control or remit of Miller and Vistry to directly control. It is the Statutory Water body’s (namely Southern Water in this instance) that have a statutory duty to meet set environmental standards as dictated by their permit. The policy needs to be clarified to make that clear. The related point in paragraph 10.21 should also be updated to reflect this position.

The bullet point should be updated to reflect the NPPF requirements.

Miller and Vistry are broadly supportive of this policy, having committed to deliver significant levels of new public open space on site. However, it is not clear from the policy what the expectations are in terms of which developments would be expected to provide indoor facilities. Given the complex nature and cost of providing indoor sports facilities, there should not be an expectation to provide such facilities unless they have formed part of the early masterplanning of the site. The West of Chichester development is masterplanned to provide space for indoor sport within the Community Building at the center of the site, along with suitable outdoor facilities.

The importance of housing delivery, and its relationship to affordability, should be made more explicit with reference to the housing crisis and the acute affordability issues in the district. The vision and objectives should also explicitly recognize the important part housing delivery plays in meeting the economic, social and environmental objectives of the NPPF.

In light of the housing crisis and the continued decreasing affordability of housing in the country as a whole and particularly within Chichester District, it is important that housing continues to be delivered in sustainable locations. The latest data release from 2021 on housing affordability shows that on average within Chichester District house prices are 14.61 times median earnings. This compares unfavorably with the West Sussex County average of 12.07 and the national average of 9.1. Chichester District remains one of the least affordable places to buy a home in the country. Furthermore, the Plan does not intend to meet the Objectively Assessed Need for housing in the district.
Whilst recognizing that the Local Plan Objectives and Vision do reference Housing, it is considered that the importance of housing delivery, and its relationship to affordability, should be made more explicit with reference to the housing crisis and the acute affordability issues in the district. The vision and objectives should also explicitly recognize the important part housing delivery plays in meeting the economic, social and environmental objectives of the NPPF.
Furthermore, it is all the more important that policies enable, rather than potentially hinder, continued delivery of new homes as far as possible, particularly on sustainable allocated sites, such as the West of Chichester. Vistry and Miller are already delivering housing on site contributing to Chichester’s housing needs.

It is suggested the Policy is reworded to make this clear in respect of affordable tenures

We have no comment on overall proposed level of affordable housing as it would relate to the West of Chichester site. Miller and Vistry are pleased that the West of Chichester site is delivering 30% affordable housing on site in accordance with Policy H4. In regards affordable tenure, we agree that there needs to be flexibility to cater to different needs, but this should also extend to management and viability considerations, as well as be flexible enough to respond to changes in national policy. It is suggested the Policy is reworded to make this clear in respect of affordable tenures.

Suggest point 1 references exceptions within point 3. Point 3 (a) provides some flexibility but is still considered too rigid to enable sites to quickly adapt to evolving housing demands.

Point 1 suggests new market and affordable homes must be delivered in line with the HEDNA. However, point 3 then provides exceptions – it is suggested point 1 references point 3 to avoid confusion.
More generally, we support providing a mix of homes of differing size, types and tenures to meet a range of local needs. However, any such policy has to be flexible enough to recognise the range of needs locally and the specifics of the site and its context. Relying solely on the HEDNA and infrequently published updates to it does not fully provide this flexibility and would not allow home builders to respond effectively to changing market conditions over the plan period, which in the current economic and political climate, can occur quickly. It also does not recognise that, within the district, and particularly on large sites such as West of Chichester, circumstances may exist which require a less prescriptive approach to housing mix on site. Furthermore, the financial viability of providing a given mix also has to be considered and allowed for in any policy wording to reflect that, particularly on larger sites, too heavy a weighting on any particular size of houses can have significant viability implications. The provisions of point 3(a) provide some flexibility but is still considered too rigid to enable sites to quickly adapt to evolving housing demands.

To avoid any potential confusion, suggest the first paragraph of the policy [H6] is amended to make it clear that the requirement for provision of self and/or custom build housing on SDLs is only required where the allocation policy explicitly requires it.

Miller and Vistry agree that given the allocation of the site is brought forward from the previous plan and the site has already been master planned, had a concept statement agreed and is at an advanced stage of consideration, it would be inappropriate to require the West of Chichester SDL to provide any self or custom build units (as confirmed by the absence of any self or custom build requirement in Policy A6).

Recommend policy H8 is reworded to make it clear that provision of specialist accommodation on SDLs will only be expected where allowed for in the relevant allocation policy, having been discussed and agreed with the relevant developer or site promoter.

We object to this policy as currently worded. Whilst recognizing there may be a need for specialist housing for older persons, the policy as worded runs counter to the provisions of the A6 West of Chichester allocation policy and masterplan for the site, neither of which include for specialist accommodation for older persons referenced in the West of Chichester Allocation policy. Miller and Vistry made comments on the regulation 18 plan (DM2 as was) to the same affect but have had no subsequent discussions with CDC about such a requirement. T
Notwithstanding the above, in response to comments from the Housing Officer to the phase 2 application, the phase 2 proposals do include a proportion of bungalows to cater for down sizers and older persons.

Whilst supportive in principle of providing accessible and adaptive housing, Miller and Vistry have concerns about the implications and soundness of the policy requirement for all dwellings to meet the M4(2) accessibility and adaptability standards. The supporting text to the policy 5.53 highlights current national consideration of changes to Building Regulations in relation to M4(2) standards. It is through the national building regulations that such standards should be implemented, particularly where they are proposed to be mandatory for all dwellings. Such an approach also does not take account of the technical and financial implications of a blanket approach or potential implications on the land take required having regard to the need to make the most efficient use of land. It is also not clear how payment of a commuted sum (the calculation for which should form part of the plan) would meet the tests.