Local Plan Review: Preferred Approach 2016-2035

We support the proposed settlement hierarchy and the designation of Southbourne as a 'Settlement Hub'. The settlement provides a range of existing facilities and services. It is also very well served by existing public transport which provides connections to larger centres such as Portsmouth, Southampton and Brighton.

We acknowledge the importance of balancing the planned housing delivery with employment provision in the interests of overall sustainable development. However, the blanket protection of existing employment sites outlined in this policy does not serve that purpose. The policy limits its support to 1) the intensification of existing employment uses and 2) in exceptional circumstances the reuse of these sites for leisure and community uses.

Based on the evidence contained within the Council's CIL Viability Assessment (2014) neither scenario is likely to be viable. In relation to office use, the Assessment states that "speculative office development produces a negative land value...We therefore recommend that a CIL Charge should not be set for office floorspace". The assessment provides similar commentary in relation to industrial and storage uses, stating that "industrial/warehouse development in Chichester is generally not viable. There is therefore no potential for sustaining a CIL charge". It is also important to note that these comments are made in the context of Greenfield Development and without the negative implications of existing use values and demolition/clearance costs.

The viability of standalone community or leisure uses (the only alternative uses considered acceptable) is also questionable given the limited economic value in these uses. The Assessment states that "some development may occur on traditional employment sites but this will be linked to specific user requirements, or through mixed use developments which incorporate office accommodation alongside other more viable uses such as residential or retail". Policy S8 ignores this evidence and provides no support for mixed use development as a means of retaining and increasing employment on existing sites that are in need of investment and regeneration.

The introductory text for Policy AL13 refers to "around 1,250" new homes whereas the policy itself refers to "a minimum of 1,250" homes. This inconsistency needs to be addressed by amending the introductory text to refer to "a minimum".

The introductory text refers to housing "to be phased throughout the plan period". This important consideration is not fully reflected in the policy wording itself, which only refers to phasing in the context of infrastructure delivery.

This strategic allocation makes a significant contribution to the District Council's overall housing requirement and furthermore it will have a strong bearing on the District Council's rolling 5-year supply of housing. Paragraph 73 of the NPPF requires strategic policies to "include a trajectory illustrating the expected rate of housing delivery over the plan period" and goes on to consider whether it is appropriate to set housing trajectories on a site-by-site basis to avoid delayed housing delivery from large strategic sites where there are complex infrastructure requirements. In this context the NPPF highlights the important contribution of small - medium sized sites and the subdivision of larger sites in maintaining a rolling 5-year supply of housing.

Please see associated comments in relation to Policy S8.

Fundamentally, the policy ignores the advice contained within the Council's CIL Viability Assessment (2014) by only allowing the redevelopment of existing employment sites in scenarios which are already known to be unviable. New employment floorspace is generally unviable in the absence of accompanying higher value uses and the policy should plan for this reality.

In addition, the policy ignores scenarios where the continued employment use of a site may be harmful for environmental reasons (inc. incompatibility with neighbouring land uses). Left unchanged the policy is at odds with Paragraph 118 of the National Planning Policy Framework (2018).