Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5773

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Procedure set out in NPPF and PPG has not been followed; overwhelming unmet need for housing not addressed in evidence for plan; no statement of common ground demonstrating how A27 cross-boundary issues has or will be resolved.

The justification for not meeting the housing needs in full is set out in the Housing Need (July 2024) and Transport (July 2024) Background Papers.

The Statement of Compliance published at the time of the Regulation 19 consultation set out the key cross boundary transport issues, the engagement undertaken by the Council with relevant bodies on these issues and the outcomes of that at that stage. The latest position is set out in the updated Statement of Compliance (April 2024) and Statements of Common Ground.

Object

Representation ID: 5774

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Vision suggests people will be able to choose from a variety of homes to suit their incomes, needs, lifestyle and stage of life in accessible locations close to existing or new services, meeting the needs of young people, families and older people. However, Plan does not propose to meet housing needs and as a result, there will be an insufficient supply to meet housing needs let alone provide choice. Households on a lower income will find it increasingly difficult to find suitable housing, households generally will find it increasingly difficult to access suitable housing regardless of needs, lifestyle and stage of life, housing needs of young people, families and older people will not be met.

The Vision is intended to be ambitious and looks ahead to 2039. The plan will be reviewed before then to see if circumstances mean a different housing number can be delivered.

Object

Representation ID: 5775

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Paragraph 2.52 suggests that strategic objectives align with the objectives of LSS2, one of which is meeting strategic housing needs. However, paragraph 5.2 of the proposed submission draft explicitly identifies that not only will the housing needs of the plan-area not be met, but also that no contribution will be made to the unmet needs of the South Downs or the sub-area more widely.

Comment noted – this paragraph does not refer to the housing target

Object

Representation ID: 5776

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.

Consideration has been given to the making of a strategic allocation at Hunston and the Preferred Approach Local Plan did propose a strategic parish requirement for 200 dwellings with sites to be allocated through the Hunston Neighbourhood Plan. However, as the Local Plan has progressed this approach has been revised to take account of the recently permitted growth on the Manhood Peninsula and specifically the infrastructure constraint at Hunston/North Mundham regarding the availability of primary school capacity to accommodate additional pupil numbers. The education authority, WSCC, has advised the Council that there would only be primary school capacity to accommodate the additional pupil numbers from 50 dwellings and that the remaining 150 dwellings (as proposed in the Preferred Approach) would need to be relocated elsewhere in the Plan Area. As set out in Policy H3, it is proposed that the 50 dwellings come forward through the North Mundham Neighbourhood Planning process (which will likely be made up from sites that have received planning permission after the base date of the plan).

Object

Representation ID: 5777

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.

The Housing Distribution Background Paper sets out the justification for the site allocations and strategic parish numbers set out in Policy H2.
The Local Plan makes provision for a limited amount of new housing development on the Manhood Peninsula. This approach takes account of the large amount of development that has received planning permission and updated technical evidence, including the SFRA which considers flood risk. This is considered in more detail in the Housing Distribution Background Paper and Sustainability Appraisal.

Promotion of site noted.

Object

Representation ID: 5778

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.

The Local Plan makes provision for a limited amount of new housing development on the Manhood Peninsula. This approach takes account of the large amount of development that has received planning permission and updated technical evidence, including the SFRA which considers flood risk. This is considered in more detail in the Housing Distribution Background Paper and Sustainability Appraisal.

Promotion of site noted.

Object

Representation ID: 5779

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that no exception circumstances for alternative approach to housing need; there is a need for at at least 666 homes per annum in plan area equating to a need for 11,988 homes over plan period; also need for at least 1,083 homes per annum if affordable housing needs are to be met equating to 19,485 homes; unmet need in excess of 10,000 homes in related authorities; capacity constraints on A27 should not limit amount of development, inconsistent with objectives of national policy.

The justification for not meeting the housing needs in full is set out in the Housing Need and Transport Background Papers (May 2024). The latest Duty to Cooperate evidence is set out in the updated Statement of Compliance.
The Plan is as positive as it reasonably can be in terms of tackling the need for affordable housing and needs of other groups

Object

Representation ID: 5780

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that proposed “monitor and manage” approach as opposed to “plan, monitor and manage” approach inherently acknowledges that Council is failing to plan to address infrastructure or housing needs; approach not consistent with national policy and will actively constrain delivery of infrastructure and housing needed; modelling data provided in Chichester Capacity Study does not provide justification for how figure of 535 dpa was arrived at, SATURN modelling shows that 700 dpa could be accommodated; requested financial contributions are for improvements on the SRN which is the responsibility of National Highways, funding received from the Department of Transport; method by which financial contributions have been calculated is flawed.

The Local Plan Transport Studies (2023 & 2024) demonstrate that taking the Local Plan forward on the basis of meeting the full housing need would require A27 junction improvements at Whyke and Stockbridge junctions (including the link road) in addition to Fishbourne and Bognor. The estimated costs for this full mitigation package would be more than £90 million. In the absence of certainty of government funding, this level of infrastructure is not deliverable and so Policy T1 takes a ‘monitor and manage approach’.
ii) The Local Plan Transport Study (Jan 2023) explains that the Chichester Area Transport Model (CATM) is based on SATURN version 11.4.07H which has been updated by Stantec to investigate travel patterns in and around the Chichester area. This included taking account of changes in response to the policies and strategy of the emerging Chichester Local Plan. Further work has since been undertaken (Local Plan Transport Study 2024) to further inform the reliability of the current model.
Undertaking new modelling work at this stage would further delay the local plan which has already been significantly delayed, and would lead to further pressures on local infrastructure.
iii) Policy T1 proposes applying contributions only to residential development to avoid ‘double counting’ impacts on the Strategic Road Network which would result from seeking contributions from employment, leisure or other types of development.

Object

Representation ID: 5782

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that HEDNA identifies need for 225 affordable ownership homes, disregarded within Plan; unclear how tenure mix has been identified - disproportionately large share of social and affordable rental homes compared to that needed; policy does not align with evidence.

The Council contend that the Local Plan does respond appropriately to the evidence set out within the HEDNA, as the plan seeks to provide as much affordable housing as is possible in light of viability constraints. In terms of the tenure mix, while this is heavily influenced by the HEDNA, which emphasises the need for social and rented accommodation, this has been balanced against other policy requirements concerning affordable housing and the protocol used by the Council’s Housing Department when providing and assigning affordable housing. The policy is considered to be an appropriate reconciliation of the evidence concerning needs, balanced against other policy and deliverability considerations

Object

Representation ID: 5783

Received: 17/03/2023

Respondent: Beechcroft Developments Limited

Agent: Genesis Town Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that developer contributions sought for improvements exclude contributions from other development types such as industrial, retail, leisure, education which all generate traffic movements but don't appear in assessments - approach to securing financial contributions towards improvements to A27 is flawed.

Policy T1 proposes applying contributions only to residential development to avoid ‘double counting’ impacts on the Strategic Road Network which would result from seeking contributions from employment, leisure or other types of development.