Schedule of Proposed Changes to the Policies Map

We write in response to the above consultation on behalf of our client, the Church Commissioners for England (CCE). CCE owns a large amount of land in the area largely to the south, west and east of Chichester.
We welcome the opportunity to further engage with the Local Plan process. Whilst we support some aspects of the Local Plan, we consider that some changes are likely to be necessary to ensure that the Plan can be found sound.

By way of background, CCE submitted several sites for consideration as part of the Housing Economic Land Availability Assessment (HELAA) in 2021. These sites were previously promoted as part of the Preferred Approach Local Plan Regulation 18 Consultation in 2019.
As part of these representations, we take the opportunity to re-promote a number of CCE’s sites, which could assist the Council in delivering much needed housing for the district. CCE has updated its technical work and provide Vision Documents in relation to its landholdings in Southbourne, Oving, and Hunston Parishes to demonstrate how additional housing can be delivered. These Vision Documents are enclosed.
We consider this and other aspects of the emerging Local Plan below.

Chapter 2: Vision & Strategic Objectives

The Local Plan Vision details a positive approach to supporting sustainable development in the context of the climate emergency. CCE welcomes the Vision for Chichester, particularly the importance placed on the delivery of new homes in ‘Objective 3’ and the delivery of new infrastructure to support the new development in ‘Objective 7’.

Chapter 3: Spatial Strategy and Settlement Hierarchy

The Spatial Strategy builds on the previous Local Plan by focussing growth on Chichester city as the main sub-regional centre. Outside Chichester city and its closest settlements, development will focus on the two settlement hubs within the east-west corridor at Tangmere and Southbourne. This approach is supported by CCE.

Policy S1 Spatial Development Strategy

Draft Policy S1 (Spatial Development Strategy) identifies the broad approach to providing sustainable development in the plan area, which includes ensuring that new residential development is distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements. We support this strategy, with particular support for development at the settlement hubs of Southbourne (Policy A13) and Tangmere (Policy A14). We also support that provision is made for extant Site Allocations and the Tangmere strategic site remains allocated under draft Policy A14.

Policy A14 continues to allocate Land West of Tangmere for 1,300 dwellings. CCE questions the Council’s decision to not amend the existing settlement boundary of Tangmere to include the land subject to the allocation. Without amending the settlement boundary, the future growth of Tangmere may be hindered. As such, the settlement boundary of Tangmere should be amended to include the allocated site to ensure that the plan is justified.

Draft Policy S1 also refers to development in service villages such as Bosham, Hambrook and Loxwood.
Hunston is excluded from the Spatial Strategy but is identified as a Service Village within the Settlement Hierarchy in draft Policy SP2 (Settlement Hierarchy). The draft Local Plan suggests that the allocation of homes in Hunston has been removed as a result of growth in the Manhood Peninsula. CCE acknowledges that the overall housing numbers across the district have been reduced as a result of local constraints but reiterate that their landholding in Hunston remains a suitable site for housing should the Council need to identify more land for housing. This is discussed further below.

Policy S2 Settlement Hierarchy

As stated in paragraph 3.31 of the draft local plan, ‘The NPPF encourages housing delivery where it will enhance or maintain the vitality of rural communities’. Paragraph 79 of the NPPF (2021) states that ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby’.

CCE owns substantial land holdings in South Mundham, which is in close proximity to North Mundham/Runcton which is defined as a Service Village. As such, whilst South Mundham does not contain any services, development in the hamlet would enable sustainable growth to support facilities in North Mundham and Runcton. To ensure that the draft plan is consistent with national policy, South Mundham should be considered as part of North Mundham as a Service Village when considering the future pairing/grouping of some settlements where the facilities and services could be shared to capitalise on the close connections some settlements have.
Development outside the settlements listed in the hierarchy in SP2 is restricted to proposals which require a countryside location or meet an essential local rural local need or supports rural diversification in accordance with Policy NE10. To this end, CCE has smaller land holdings in Tangmere, Oving, South Mundham, Birdham, Chidham and Sidlesham, which may be suitable for conversion for residential use or via windfall housing. Location plans for each of the sites can be found in Appendices 1-8.

Chapter 4: Climate Change and the Natural Environment

Policy NE4 Strategic Wildlife Corridors

The East of City strategic wildlife corridor has been relocated to the eastern side of proposed Site Allocation A8 (Land to the East of Chichester). The relocation of this wildlife corridor follows additional evidence that shows that the commuting route for Barbastelle Bats is along Drayton Lane.

CCE owns land to the east of Drayton Lane (immediately adjacent to the wildlife corridor and to the east of draft allocation A8) and surrounding the village of Oving. Its land has been identified in the HELAA (2021) as being developable, including site HOV0017 (Drayton Lane). The land east of Drayton Lane is sustainably located being close to Chichester and its amenities. The site provides an opportunity to sensitively and sustainably provide additional homes for the District. In accordance with Draft Policy NE4, the proposals for the Land East of Drayton Lane will not have an adverse impact on the integrity and function of the wildlife corridor and will not undermine the connectivity and ecological value of the corridor. This Vision Document will be shared under separate cover.

The eastern edge of the relocated wildlife corridor encroaches into CCE land. Any proposal on this land would be required to take the statutory protection for bats and other protected species into consideration and managed as part of a sensitive masterplan for development and on this basis, it is considered unnecessary to extend the wildlife corridor to encroach into the CCE site.

It is also considered that the detail of policy NE4 goes beyond the purpose of the policy, which should be to safeguard wildlife rich habitats and wider ecological networks. The policy is clear that development should only be permitted where it would not create an adverse effect upon the ecological value, function, integrity and connectivity of the corridors. It does not resist development in principle. This therefore makes redundant policy text 1, which seeks to introduce a sequential test for preferable sites outside of a wildlife corridor. It is considered that this test conflicts with the underlying purpose of the policy, which is to safeguard wildlife corridors from harmful impacts that cannot be mitigated, and should therefore be deleted.

Policy NE7 Development and Disturbance of Birds

CCE is broadly supportive of Policy NE7. However, they would like to note that the situation regarding the national guidance on nutrient neutrality is still evolving and therefore, this policy is only relevant to current legislation. Policy NE7 may therefore not be relevant throughout the entirety of the plan period. As such, CCE considers that it is necessary in this instance to ensure that an appropriate reference to changing legislation is included within the policy to prevent it from becoming out of date and would also ensure that the policy remains effective once adopted.

Policy NE10 The Countryside

CCE is supportive of the inclusion of a policy referencing the conversion of existing buildings in the countryside, however, we believe that Policy NE10 is not consistent with national policy. Policy NE10 criteria B states that proposals for the conversion of buildings in the countryside will be permitted where ‘it has been demonstrated that economic and community uses have been considered before residential, with residential uses only permitted if economic and community uses are shown to be inappropriate and unviable’. This policy is not in accordance with Paragraph 152 of the NPPF (2021) which states that the reuse of existing resources should be encouraged, including ‘the conversion of existing buildings’. Under paragraph 152, there is no prerequisite to adopt a sequential approach, or to give preference to other uses. As such, criteria B should be omitted from Policy NE10. Reference to criteria B should also be removed from criteria C.

Chapter 5: Housing

Policy H1 Meeting Housing Needs

The Preferred Approach Local Plan was based on meeting the identified objectively assessed housing needs of the plan area of 638 dwellings per annum. However, due to constraints, particularly the capacity of the A27, the Submission Version of the Local Plan has planned for a housing requirement below the need derived from the standard method. The Plan proposes to deliver 535 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 (575 dpa).

The Planning Inspectorate has previously asked the Council to determine what level of housing could be achieved based on deliverable improvements to the A27 and to consider whether the full housing needs could be met another way. It is acknowledged that the Council has carried out the additional work required and the local constraints have resulted in a proposed lower housing requirement.

The NPPF (2021) confirms that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach (para. 61). CCE acknowledges that that housing numbers have been reduced as a result of local constraints and it will be down to the Inspector to determine whether the Council’s exceptional circumstances justify this. Should the Planning Inspector find that the Council requires additional land to meet the housing need using the standard method, CCE’s land at Southbourne, Oving, Drayton Land and Hunston are suitable, available and developable for housing. In addition, CCE’s rural development sites could also contribute to meeting the housing need.

Policy H2 Strategic Allocations

Draft Policy H2 confirms that the Tangmere Strategic Development Location is carried forward from the 2015 Local Plan and this is supported by CCE. Strong support is also given for the Broad Location of Development in Southbourne (Policy A13) for up to 1,050 dwellings.

Policy H5 Housing Mix

Draft Policy H5 confirms that the housing mix for a development will be based on the most up to date HEDNA to address identified local needs and market demands. We suggest that the Council considers a range of criteria, including site characteristics, when determining the housing mix for individual sites and this should be reflected in wording of Policy H5.

Policy H7 Rural and First Homes Exception Sites

Draft Policy H7 relates to rural and first homes exception sites. CCE is supportive of the principle of the inclusion of a rural exceptions policy. However, we have concerns over criteria contained within the policy which limits the amount of development that can be delivered under it.

The NPPF (2021) at paragraph 78 states that planning policies and decisions should be responsive to local circumstances and support housing development that reflect local needs. Furthermore it also states that ‘local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs’.

The key aspect of the policy is to enable the delivery of rural exception sites which would address an identified local need. Within the policy, there is no limit on the amount of development that can be delivered and therefore, it is considered that if Policy H7 is limited to a maximum of 30 dwellings it could serve to hinder development (especially on slightly larger sites), which would otherwise be sustainable. As such, we consider that the amount of development should not be limited and rather should be dictated on a site and need specific basis. CCE considers that for Policy H7 to be positively prepared and in accordance with National Policy, criteria 2 should be removed.

In addition, criteria 6 states that proposals for affordable housing on rural exception sites will only be supported where ‘the site is located adjacent or as close as possible to the existing settlement boundary and does not result in scattered or isolated development in rural areas’. The NPPF (2021) does not specify the location of rural exception sites. As such, to be consistent with national policy, criteria 6 should also be omitted.

Furthermore, Policy H7 states that ‘applications for first homes exception sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence…’.
However, in the policy there is no allowance for the provision of market housing on rural exception sites in addition to first homes exception sites. As a result of this, the requirements of the policy are again not consistent with national policy. Paragraph 78 of the NPPF (2021) is supportive of ‘some market housing’ where it would facilitate the delivery of rural exception sites. As such, CCE considers that Policy H7 should be amended as follows:

‘Applications for rural and first homes exceptions sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence that the site would be unviable without such housing being included’.

Policy H8 Specialist Accommodation

Draft Policy H8 confirms that all housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people with a support or care component. We request that this policy is amended to add ‘where appropriate and viable’, acknowledging that viability and site-specific factors need to be taken into consideration.

Chapter 6: Place-making

Policy P3 Density

We support the objective of Draft Policy P3 (Density) to make the most efficient use of land and follow a design led approach to achieve the optimum density for a site. The Policy does not prescribe an appropriate density for the District and this is supported. However, we consider that reference should be made to the fact that density may vary depending upon site specific circumstances and could be higher where transport links and access to services is good.

Chapter 7: Employment and Economy

Policy E3 and E4 Horticultural Development

Chapter 7 of the draft Local Plan confirms that 67 hectares of land is identified to meet the future horticultural land need within four Horticultural Development Areas (HDAs) over the plan period. It is confirmed that an additional 137 hectares of horticultural land is also forecast to be required outside of HDAs to meet future need.

CCE has significant landholdings which could assist the Council in addressing the insufficient availability within the current HDAs. The CCE sites which are considered suitable for horticulture development are listed below and location plans for each of the sites can be found in Appendices 9-13.
• Somerley Farm, NE East Wittering, PO20 7JB
• Fisher Farm, South Mundham, PO20 1ND
• Church & Haise Farm, Sidlesham
• Cowdry Farm, Birdham
• Groves Farm, nr Merston, PO20 2DX / Colworth Manor Farm PO20 2DU.

CCE supports draft Policy E3 which confirms that “approximately 137 hectares of land is also needed outside of HDAs to meet anticipated horticultural and ancillary development land need for the plan period.” Support is also given for draft Policy E4 in relation to land outside HDAs. This Policy confirms that proposals for horticultural development can come forward outside the HDAs, subject to a set of criteria. We would welcome continued discussion with the Council on how these sites could help meet the districts horticultural needs in the future.

Chapter 10: Strategic and Area Based Policies

CCE supports Chichester District Council’s proposal to allocate additional land for housing at
Southbourne and to maintain the existing allocation at Tangmere. We also consider that CCE’s land at Hunston and Oving could assist the Council in meeting its housing needs, should additional housing be required. We consider these opportunities in turn below.

Policy A13 Southbourne Broad Location for Development

CCE supports draft Policy A13 and the allocation of a Broad Location for Development in Southbourne for a mixed-use form of development including 1,050 dwellings.

CCE has significant landholdings around Southbourne which is suitable, available and developable. The land to the north and west of Southbourne measures 70ha and is wholly within CCE’s control. The land adjoins the existing settlement and provides an opportunity for a sustainable extension to Southbourne with the potential to deliver c. 1,200 homes for the village, as well as employment, community uses and a significant amount of new public space and green open space. A new Vision Document is enclosed which explains one way in which this opportunity could be realised. Importantly, it is considered that there are no technical impediments that would prevent development from coming forward on this site.

This site has been promoted throughout the Southbourne Neighbourhood Plan process, most recently in the December 2022 consultation. The new Vision Document demonstrates that the CCE site presents the opportunity to provide a comprehensive development that would contain strategic housing growth, significant areas of green infrastructure and open space in a sustainable location. The key access strategy for the site is to provide two new access points from the south A259 Main Road and the east Stein Road. These access points would connect to a spine road which would form a continuous vehicle route around the north-western edge of Southbourne.

The site almost entirely comprises a Secondary Support Area under the Solent Waders and Brent Goose Strategy (SWBGS), which aims to protect the network of non-designated terrestrial wader and brent goose sites that support the Solent Special Protection Areas (SPA) from land take and recreational pressure associated with new development. Due to the designation of the site, discussion was undertaken with the Hampshire and Isle of Wight Wildlife Trust with a view to determine a suitable approach for the scheme and an appropriate survey effort to establish the use of the site by designated birds. As a result of these discussions, wintering bird surveys are taking place. The aim of these surveys is to explore opportunities for mitigation for this SWBGS support area such that development within the red line can proceed without adverse impacts to the bird populations noted within this strategy. Following the survey, the results and approach will be presented to Natural England for further discussion.

In relation to viability, we note that Policy A13 sets several policy objectives for development at Southbourne. The NPPF (2021) notes that where there are up-to-date policies which have set out the contributions expected from development, planning applications that comply with them should be assumed to be viable (para. 58). With this in mind the policy objectives outlined within Policy A13 will require viability testing to be undertaken to ensure a policy compliant scheme is both viable and deliverable. This is necessary to ensure that the policy is sound.

The Policy suggests that employment opportunities are required to be delivered as part of the allocation but there is no specific reference to the amount of use required. CCE supports this proposed approach as it is sufficiently flexible to enable an amount of employment land to be proposed in response to market conditions at the appropriate time and this will help to support delivery of the allocation.

The scale of development proposed has been reduced from 1,250 to 1,050 dwellings to reflect the proportionate reduction in housing numbers across the parishes in the east west corridor as a consequence of the limit on numbers in the southern plan area. If the Inspector finds that additional housing is required, the Vision Document submitted demonstrates that the CCE site in Southbourne could deliver c. 1,200 homes and so could increase housing without needing to identify additional land for development elsewhere.

To summarise, the site could accommodate approximately 1,200 homes which could be delivered on a phased basis early in the plan period. There are no overriding physical or technical constraints that would act as an impediment to development. There is also a clear access arrangement proposed.

Policy A14 Land West of Tangmere

CCE supports that Policy A14 is carried forward into this Local Plan to facilitate the delivery of a residential-led development of at least 1,300 dwellings.

Additional sites

Hunston

CCE further promotes land (15.31ha) located east of the B2145 Selsey Road in Hunston for 240 new homes. The land is deliverable and is fully within CCE’s control. The site is highly accessible, located within a maximum of 5-6 minutes walking distance to Selsey Road, where several bus routes connect the village to Chichester.

CCE notes that the Council assessed the HELAA site (ref. HHN0016) as ‘developable’. A Vision Document has previously been prepared and submitted to demonstrate the commitment to it being brought forward for residential development within the plan period. This document is enclosed.

To address the Council’s concerns in relation to flooding, following publication of the Chichester Strategic Flood Risk Assessment (SFRA), we have prepared an updated Flood Risk Scoping Study which provides an overview of flood risk constraints across the site from a range of sources. Various mitigation measures are recommended in line with recommendations of the Chichester SFRA and prevailing local and national guidance and best practice. With these measures in place, it is likely that the flood risk could be managed effectively in accordance with the requirements of the NPPF. Detailed data has also been requested from the Environment Agency, which will feed into further technical work that is being carried out.

Should the Inspector conclude that additional housing is required, CCE considers that their site is the most appropriate and sustainable location for development in Hunston. The site provides an opportunity to sensitively and sustainably extend the existing village boundary to provide additional homes to meet an identified housing need.

Land East of Drayton Lane

CCE owns land to the east of Drayton Lane which is bound by Tangmere Road to the north and crosses Oving Road and the railway line to the south. The site is c.1km from the centre of Chichester and comprises 49ha. The site was assessed in the HELAA 2021 as developable ‘HOV0017’. A Vision Document has been prepared and was presented to the Council in 2022. This includes a detailed analysis of the site and its surroundings and provided justification as to why the site is suitable for development. This technical review of the site concludes there are no technical impediments to development.

The Vision Document demonstrates how the proposals for the land east of Drayton Lane could be developed as an extension to the draft allocation A8 (Land to the east of Chichester) for up to 700 new homes. The land east of Drayton Lane is fully within the CCE’s control, is available for development now and is deliverable with some development achievable within the first five years of the plan period. It represents an opportunity to provide new homes, facilities and significant community benefits, through a sensitively designed development that integrates into the surrounding landscape.

The Vision for this site is a landscape and ecology led masterplan which would celebrate the rich wildlife characters of the different surrounding landscapes and uses the connection between countryside and community to generate its character and identity. The Vision Document demonstrates that this is a suitable location for development.

Should the Inspector conclude that additional housing is required, CCE considers that the land east of Drayton Lane would form a natural extension to allocation A8 and is an appropriate and sustainable location for new development.

Appendix C Additional Guidance
Appendix C provides additional guidance on evidence which needs to be submitted in support of certain planning applications related mainly to development in the countryside. As mentioned in the comments above provided in response to Policy NE10, there is no prerequisite contained within the NPPF (2021) that requires an applicant to demonstrate that previous uses were proven unviable prior to the conversion of a building in the countryside to residential use. As such, to be in accordance with national policy, reference to Policy NE10 should be omitted from Appendix C.

Conclusion

CCE welcomes the opportunity to comment on the Local Plan and is keen to continue to engage with the Council, especially in relation to the Broad Location for Development in Southbourne. CCE is supportive of the Council’s aspirations in the Local Plan. However, the changes set out above are considered likely to be necessary to ensure the plan is sound.

CCE is a considerable landowner in Chichester with land largely to the south, west and east of
Chichester which could assist the Council in meeting their housing and development needs throughout the plan period.

See attachments for site information.