Local Plan Review: Preferred Approach 2016-2035

S4:
Loxwood is identified by the draft Plan as a larger service village. At Paragraph 3.16 the draft Plan states that its role as a service village should be developed and that the village has wider development potential. In view of this the Local Plan allocates Loxwood to provide 125 dwellings over the plan period. Whilst we support this Policy and approach in relation to Loxwood we consider that this figure should be increased to be consistent with similar or smaller sized villages in the District.
Increase the level of housing identified in Loxwood in line with similar or smaller sized villages within the District.

S5:
We object to Policy Reference S5 on the basis that it leaves a significant degree of housing to be identified through Neighbourhood plans including 125 dwellings at Loxwood. It is considered that the Local Plan review therefore fails to have been positively prepared as it should take a more direct approach to allocating sites particularly for the larger villages where a significant amount of housing has been planned (such as at Loxwood).
The total number of dwellings that the Council relies upon for delivery by neighbourhood Plans would be approximately 3,050, this includes 200 dwellings at Hunston, 1,250 dwellings at Southbourne, 250 dwellings at Fishbourne, 500 dwellings at Chidham and Hambrook, 350 dwellings at East Wittering/Brackleshamm, 500 dwellings to be delivered through 'nonstrategic' Neighbourhood Plans (including 125 dwellings at Loxwood). In total this would mean that over 24% of the Council's future housing land supply would need to be accounted for by Neighbourhood Plans. It is our view that this is not an
appropriate strategy to deliver the significant amount of housing required within the District particularly taking into account the long standing infrastructure constraints for the delivery of housing and the requisite shortfall in the delivery of housing sites.
Should Neighbourhood Plans not be forthcoming within 6 months Policy S5 suggests that the District Council will then take on responsibility for allocating sites.
In many cases, we are aware that a number of Parish Councils will be objecting to this consultation and the suggested delivery of housing within their area. Therefore it is unlikely that all Parish Council's will respond positively to this process, particularly where they already have a recently made Neighbourhood Plan. Therefore it is considered that this approach to the delivery of housing would not be effective. Ultimately, we consider that it would require a further Local Plan review (or an additional allocations DPD) and lead to uncertainty for local residents and delays to meet the urgent need for housing within the District.
With respect to the above we note that the Council's July 2018 Local Development Scheme indicates that they expect to begin work on a Site Allocations DPD in September 2020 with adoption anticipated in Summer 2022. This would be a further 3-4 year delay in ensuring that smaller settlements within Chichester are delivering a sufficient supply of dwellings to meet housing needs.
Whilst the Inspector in part agreed with this approach when considering the previous Local Plan, this was on the basis that Neighbourhood Plans would be forthcoming and would be built from work carried out on the Local Plan. However, in many cases, relevant Neighbourhood Plans have now been made and will no longer be based on the latest background studies, or indeed the Local Plan itself once it has been adopted. Furthermore, having gone through the process of producing Neighbourhood Plan's only very recently, many Parish Council's will not have the desire or resources to review these immediately to allocate the level of housing identified in the plan.
The Inspector also thought that this approach was acceptable because at the time the Council were progressing a small housing site allocation DPD. This DPD has now been adopted and in reality has delivered on a small amount of sites which have not contributed significantly to the housing supply position. It is considered that it would not be appropriate to wait to deliver such sites through a further DPD, or a further Local Plan review as it will only result in continued delays and uncertainty over the delivery of housing.
Further to the above it is noted that the Council has relatively recently lost appeals on the basis that they are not able to provide a 5-year housing supply. The last of these being in late 2017. Since then Appeals have been found in favour of the Council but in any case It is clear that the Council's 5-year housing land supply has been tenuous at best and relies on interpretation of the deliverability and progress of approved schemes.
Considering the long standing and identified shortfall of housing in Chichester it is
considered that leaving such a significant amount of housing for delivery through
Neighbourhood Plans is inappropriate particularly bearing in mind that a number of Parish Councils have only recently made Neighbourhood Plans and have not begun any formal review process.
Therefore it is considered that the Council should be more pro-active in identifying
appropriate sites or general locations for housing to ensure that the required infrastructure can be delivered at the appropriate stage and the deliverability of sites can be secured.
The Local Plan should allocate suitable land for development, such as land at Hawthorne Cottage, Loxwood. This land is suitable, available and achievable as identified by the Chichester Housing and Economic Land Availability Assessment (under reference HLX0003). It is considered that the site is well related to existing development within Loxwood and would be able to accommodate houses in a sustainable manner.