A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023
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A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023
Planning Contributions
Representation ID: 6439
Received: 03/11/2023
Respondent: Wates Developments
- Concerns that the proposed approach does not accord with the PCPA 2004; concerns are detailed in appendix 1;
- Concerns regarding the level of contributions sought and consequential adverse impact on development viability;
- Consider the emerging Local Plan 'cap' to not be supported by evidence (Local Plan Review Transport Assessment);
- Consider the proposed 'per bedroom' tariff to be irrational; expanded further within Appendix 2
We have serious concerns that the proposed approach the Council are seeking to pursue through this SPD does not accord with the legislative framework as detailed within the 2004 Planning and Compulsory Purchase Act (as amended). Our concerns are expanded on in detail within the appended Opinion (Appendix 1), prepared by Matthew Henderson of Landmark Chambers.
In simple terms, we do not believe the Council can pursue the approach advocated in the SPD, which is to collect financial contributions for growth anticipated in an emerging (and unadopted) Local Plan.
We have concerns with respect to the levels of contributions being sought and the adverse impact on
development viability which would flow from this. The current emerging Local Plan ‘cap’ of 535 dwellings per
annum is not supported by the Council’s own evidence base, namely the Local Plan Review Transport
Assessment (LPRTA).
Furthermore, it is not rational to pursue a tariff based on a “per bedroom” basis where larger properties would be occupied by children who do not drive a vehicle. These matters are expanded upon further in the appended note, prepared by i-Transport (Appendix 2).
The adoption of this SPD should not be taken forward because the Council’s suggested approach is not in
compliance with the legislative framework or the NPPF. A27 mitigation is a matter that needs to be tested through a formal Examination in Public, associated with the emerging Local Plan.
The LPTRA shows that a 700 dwellings per annum, or more, could be delivered through the emerging Local Plan. The forthcoming Examination in Public of the emerging Local Plan could therefore result in a higher level of housing delivery which, if the Council’s approach to A27 mitigation is found to be acceptable, would bring costs down on a ‘per dwelling’ basis.
All of these issues point towards the necessity of addressing this matter through the Local Plan process,
rather than trying to avoid the necessary scrutiny through the ‘lighter touch’ SPD consultation/adoption process.
