A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023

Viability Testing

Paragraph 2.15 of the draft SPD identifies that CDC have tested various levels of contribution ranging from £3,000 to £8,000 per dwelling and the outcome of that testing was that the majority of development scenarios were found to provide the required level of funding. The draft SPD then proceeds to explain at paragraph 4.16 that, factoring in the
proposed number of dwelling to come forwards under the emerging Local Plan, this would equate to £7,623 per dwelling. However, it is noted in paragraph 4.18 that this level of contribution was not viable for scenarios comprising solely of flats on brownfield sites, nor for ‘Extra Care’ schemes nor older persons sheltered housing. The details of the viability testing have not been provided for review and SUEZ believe it is critical that the viability
testing methodology and outcomes are made available for review.

Paragraph 4.19 then proceeds to present the case for applying a sliding scale of contributions based on the number of bedrooms. It is stated that, “Smaller dwellings
generally have fewer occupants who drive and own a car and therefore have a generally smaller impact than is the case with larger dwellings where the larger number of
occupants would, on average, own and drive more cars.” SUEZ fundamentally disagrees with this statement; there is no evidence presented with the draft SPD to support this assertion and SUEZ requests that the Council’s evidence to support this statement is made available for scrutiny. This assertion doesn’t acknowledge that larger homes accommodate families with children occupying separate bedrooms; Section 325 of the Housing Act 1985 (the ‘room standard’) states that a household may be statutorily overcrowded where children of the opposite sex over the age of 10 have to share a room. Larger homes are therefore required for larger families to prevent overcrowding.

The evidence that larger homes equates to greater car ownership is not presented and it is SUEZ’s view that without supporting evidence, the proposed sliding scale of
contributions presented in paragraph 4.23 is not justified.
In addition, no viability testing has been carried out for contributions above £8,000 per dwelling (paragraph 2.15 expressly states that viability testing was carried out to a
maximum of £8,000 per dwelling).

In summary, SUEZ objects to the concept of a bedroom-based contribution scale and we object to the contribution figures presented in paragraph 4.23 because:
- Figures above £8000 have not been reviewed through CDC’s viability testing.
- No Viability Testing methodology or outcomes are presented for review.
- No justification is provided to support CDC’s assertion that larger homes result in a greater vehicle ownership.

Finally, it a bedroom-based sliding scale of contributions provides uncertainty for land owners and for developers which may hinder the development of future housing.

SUEZ suggest that further information should be made available during a further round of consultation; specifically to include details of CDC’s Viability Testing methodology and justification for proposed contributions.

Paragraph 1.1

Paragraph 1.1 provides the reasoning that the 2016 Planning Obligations & Affordable Housing SPD is being updated due to emerging evidence associated with the preparation of the emerging Chichester Local Plan 2021-2039.

CDC’s current Planning Obligations & Affordable Housing Supplementary Planning Document (SPD) was adopted in 2016; notably after the Examination and Adoption of
CDC’s current Local Plan (adopted in July 2015). CDC’s proposal to amend this SPD based on emerging technical evidence prepared for the Chichester Local Plan 2021-2039 appears to be premature; the evidence has not yet had the opportunity to be reviewed through the Plan Examination process.

SUEZ suggest that CDC awaits the completion of the Examination in Public for the Chichester Local Plan 2021-2039 before adopting a new level of contributions.

Paragraph 2.13 and 4.9

Paragraphs 2.13 and 4.9 both reference a limit of 9,630 dwellings. It is SUEZ’s view this should be amended to read, “…approximately 9,630 dwellings.”

Viability Testing

Paragraph 2.15 of the draft SPD identifies that CDC have tested various levels of contribution ranging from £3,000 to £8,000 per dwelling and the outcome of that testing was that the majority of development scenarios were found to provide the required level of funding. The draft SPD then proceeds to explain at paragraph 4.16 that, factoring in the
proposed number of dwelling to come forwards under the emerging Local Plan, this would equate to £7,623 per dwelling. However, it is noted in paragraph 4.18 that this level of contribution was not viable for scenarios comprising solely of flats on brownfield sites, nor for ‘Extra Care’ schemes nor older persons sheltered housing. The details of the viability testing have not been provided for review and SUEZ believe it is critical that the viability
testing methodology and outcomes are made available for review.

Paragraph 4.19 then proceeds to present the case for applying a sliding scale of contributions based on the number of bedrooms. It is stated that, “Smaller dwellings
generally have fewer occupants who drive and own a car and therefore have a generally smaller impact than is the case with larger dwellings where the larger number of
occupants would, on average, own and drive more cars.” SUEZ fundamentally disagrees with this statement; there is no evidence presented with the draft SPD to support this assertion and SUEZ requests that the Council’s evidence to support this statement is made available for scrutiny. This assertion doesn’t acknowledge that larger homes accommodate families with children occupying separate bedrooms; Section 325 of the Housing Act 1985 (the ‘room standard’) states that a household may be statutorily overcrowded where children of the opposite sex over the age of 10 have to share a room. Larger homes are therefore required for larger families to prevent overcrowding.

The evidence that larger homes equates to greater car ownership is not presented and it is SUEZ’s view that without supporting evidence, the proposed sliding scale of
contributions presented in paragraph 4.23 is not justified.
In addition, no viability testing has been carried out for contributions above £8,000 per dwelling (paragraph 2.15 expressly states that viability testing was carried out to a
maximum of £8,000 per dwelling).

In summary, SUEZ objects to the concept of a bedroom-based contribution scale and we object to the contribution figures presented in paragraph 4.23 because:
- Figures above £8000 have not been reviewed through CDC’s viability testing.
- No Viability Testing methodology or outcomes are presented for review.
- No justification is provided to support CDC’s assertion that larger homes result in a greater vehicle ownership.

Finally, it a bedroom-based sliding scale of contributions provides uncertainty for land owners and for developers which may hinder the development of future housing.

SUEZ suggest that further information should be made available during a further round of consultation; specifically to include details of CDC’s Viability Testing methodology and justification for proposed contributions.

Paragraph 1.1

Paragraph 1.1 provides the reasoning that the 2016 Planning Obligations & Affordable Housing SPD is being updated due to emerging evidence associated with the preparation of the emerging Chichester Local Plan 2021-2039.

CDC’s current Planning Obligations & Affordable Housing Supplementary Planning Document (SPD) was adopted in 2016; notably after the Examination and Adoption of
CDC’s current Local Plan (adopted in July 2015). CDC’s proposal to amend this SPD based on emerging technical evidence prepared for the Chichester Local Plan 2021-2039 appears to be premature; the evidence has not yet had the opportunity to be reviewed through the Plan Examination process.

SUEZ suggest that CDC awaits the completion of the Examination in Public for the Chichester Local Plan 2021-2039 before adopting a new level of contributions.

Paragraph 2.13 and 4.9

Paragraphs 2.13 and 4.9 both reference a limit of 9,630 dwellings. It is SUEZ’s view this should be amended to read, “…approximately 9,630 dwellings.”

Viability Testing

Paragraph 2.15 of the draft SPD identifies that CDC have tested various levels of contribution ranging from £3,000 to £8,000 per dwelling and the outcome of that testing was that the majority of development scenarios were found to provide the required level of funding. The draft SPD then proceeds to explain at paragraph 4.16 that, factoring in the
proposed number of dwelling to come forwards under the emerging Local Plan, this would equate to £7,623 per dwelling. However, it is noted in paragraph 4.18 that this level of contribution was not viable for scenarios comprising solely of flats on brownfield sites, nor for ‘Extra Care’ schemes nor older persons sheltered housing. The details of the viability testing have not been provided for review and SUEZ believe it is critical that the viability
testing methodology and outcomes are made available for review.

Paragraph 4.19 then proceeds to present the case for applying a sliding scale of contributions based on the number of bedrooms. It is stated that, “Smaller dwellings
generally have fewer occupants who drive and own a car and therefore have a generally smaller impact than is the case with larger dwellings where the larger number of
occupants would, on average, own and drive more cars.” SUEZ fundamentally disagrees with this statement; there is no evidence presented with the draft SPD to support this assertion and SUEZ requests that the Council’s evidence to support this statement is made available for scrutiny. This assertion doesn’t acknowledge that larger homes accommodate families with children occupying separate bedrooms; Section 325 of the Housing Act 1985 (the ‘room standard’) states that a household may be statutorily overcrowded where children of the opposite sex over the age of 10 have to share a room. Larger homes are therefore required for larger families to prevent overcrowding.

The evidence that larger homes equates to greater car ownership is not presented and it is SUEZ’s view that without supporting evidence, the proposed sliding scale of
contributions presented in paragraph 4.23 is not justified.
In addition, no viability testing has been carried out for contributions above £8,000 per dwelling (paragraph 2.15 expressly states that viability testing was carried out to a
maximum of £8,000 per dwelling).

In summary, SUEZ objects to the concept of a bedroom-based contribution scale and we object to the contribution figures presented in paragraph 4.23 because:
- Figures above £8000 have not been reviewed through CDC’s viability testing.
- No Viability Testing methodology or outcomes are presented for review.
- No justification is provided to support CDC’s assertion that larger homes result in a greater vehicle ownership.

Finally, it a bedroom-based sliding scale of contributions provides uncertainty for land owners and for developers which may hinder the development of future housing.

SUEZ suggest that further information should be made available during a further round of consultation; specifically to include details of CDC’s Viability Testing methodology and justification for proposed contributions.

Paragraph 1.1

Paragraph 1.1 provides the reasoning that the 2016 Planning Obligations & Affordable Housing SPD is being updated due to emerging evidence associated with the preparation of the emerging Chichester Local Plan 2021-2039.

CDC’s current Planning Obligations & Affordable Housing Supplementary Planning Document (SPD) was adopted in 2016; notably after the Examination and Adoption of
CDC’s current Local Plan (adopted in July 2015). CDC’s proposal to amend this SPD based on emerging technical evidence prepared for the Chichester Local Plan 2021-2039 appears to be premature; the evidence has not yet had the opportunity to be reviewed through the Plan Examination process.

SUEZ suggest that CDC awaits the completion of the Examination in Public for the Chichester Local Plan 2021-2039 before adopting a new level of contributions.

Paragraph 2.13 and 4.9

Paragraphs 2.13 and 4.9 both reference a limit of 9,630 dwellings. It is SUEZ’s view this should be amended to read, “…approximately 9,630 dwellings.”