Sustainability Appraisal and Habitats Regulation Assessment

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.